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Lewis Voting Rights Advancement Act (Rep. Sewell, 216 cosponsors) HR 22, SAVE Act (Rep. Roy, 110 cosponsors)--passed the House 220-208 on April 10th HR 51, Washington, D.C. Admission Act (Rep. Norton, 191 cosponsors) HR 55, a bill to repeal the National Voter Registration Act (Rep. Biggs, 1 cosponsor) HR 58, Voter Integrity Protection Act (Rep. Biggs, 1 cosponsor) HR 126, Students Voicing Opinions in Todays Elections (VOTE) Act (Rep. Al Green, no cosponsors) HR 154, Election Day Act (Rep. Fitzpatrick, 1 cosponsor) HR 155, Let America Vote Act (Rep. Fitzpatrick, 3 cosponsors) HR 156, Securing Our Elections Act (Rep. Fitzpatrick, no cosponsors) HR 160, Restoring Faith in Elections Act (Rep. Fitzpatrick, no cosponsors) HR 529, Restoring American Confidence in Elections (RACE) Act (Rep. Pfluger, 1 cosponsor) HR 723, Protect American Election Administration Act (Rep. Cole, 9 cosponsors) HR 738, Universal Right to Vote by Mail Act (Rep. Salinas, 8 cosponsors) HR 882, No Foreign Persons Administering Our Elections Act (Rep. Pfluger, 9 cosponsors) HR 884, a bill to prohibit individuals who are not citizens of the United States from voting in elections in the District of Columbia and to repeal the Local Resident Voting Rights Amendment Act of 2022 (Rep. Pfluger, 10 cosponsors)--passed the House on June 10th HR 1467, POLE Act (Rep. Garbarino, no cosponsors) HR 2499, A bill to codify Executive Order 14248, entitled \"Preserving and Protecting the Integrity of American Elections\" (Rep. Hamadeh, 2 cosponsors) HR 2561, One Vote One Choice Act (Rep. Lawler, 2 cosponsors) HR 2562, District of Columbia One Vote One Choice Act (Rep. Lawler, 2 cosponsors) HR 2694, Election Results Accountability Act (Rep. Obernolte, 7 cosponsors) HR 2803, Protecting Election Administration from Interference Act (Rep. Veasey, 5 cosponsors) HR 2847, Vote At Home Act (Rep. Hoyle, 13 cosponsors) HR 2968, Business Over Ballots Act (Rep. Roger Williams, 12 cosponsors) HR 3040, Preventing Ranked Choice Corruption Act (Rep. Hamadeh, 1 cosponsor) S 51, Washington, D.C. Admission Act (Sen. Van Hollen, 43 cosponsors) S 128, SAVE Act (Sen. Lee, 28 cosponsors) S 1240, Defending America's Future Elections Act (Sen. Padilla, 12 cosponsors) S 1887, Vote at Home Act (Sen. Wyden, 12 cosponsors) S 2124, Election Worker Protection Act (Sen. Klobuchar, 16 cosponsors) Money in Politics Bills in the 119th Congress HR 415, Stop Act (Rep. Boyle, no cosponsors) HR 535, Inaugural Fund Transparency Act (Rep. Scanlon, 11 cosponsors) HR 1399, Prior Approval Reform Act (Rep. Amodei, no cosponsors) HR 2352, Abolish Super PACs Act (Rep. Summer Lee, 6 cosponsors) HR 2356, Dual Loyalty Disclosure Act (Rep. Massie, 3 cosponsors) HR 2476, Stop Illegal Campaign Coordination Act (Rep. Tokuda, 4 cosponsors) HR 2498, End Dark Money Act (Rep. Crow, 1 cosponsor) HR 2816, Shell Company Abuse Act (Rep. Bell, 3 cosponsors) HR 3311, Eliminating Leftover Expenses for Campaigns from Taxpayers (ELECT) Act (Rep. Steube, no cosponsors) HR 3535, Stop Foreign Funds in Elections Act (Rep. Fitzpatrick, 1 cosponsor) S 118, Inaugural Fund Transparency Act (Sen. Cortez Masto, 4 cosponsors) S 538, ELECT Act (Sen. Ernst, no cosponsors) S 1849, ZOMBIE Act (Sen. Bennet, no cosponsors) SJ Res 43, Democracy for All Amendment (Sen. Shaheen, 40 cosponsors) Redistricting/Census Bills in the 119th Congress HR 158, CLEAN Elections Act (Rep. Fitzpatrick, 1 cosponsor) HR 2797, House Expansion Commission Act (Rep. Stevens, 1 cosponsor) HR 3877, a bill to provide for the retrocession of the District of Columbia to Maryland (Rep. Griffith, no cosponsors) Ethics, Lobbying, and Other Government Reform Bills in the 119th Congress HR 253, Bipartisan Restoring Faith in Government Act (Rep. Fitzpatrick, 3 cosponsors) HR 358, No Corruption in Government Act (Rep. Nunn, 1 cosponsor) HR 396, TRUST in Congress Act (Rep. Magaziner, 76 cosponsors) HR 1074, Supreme Court Term Limits and Regular Appointments Act (Rep. Khanna, 8 cosponsors) HR 1712, Modern Emoluments and Malfeasance Enforcement (MEME) Act (Rep. Liccardo, 18 cosponsors) HR 1883, Lobbying Disclosure Improvement Act (Rep. Miller-Meeks, 1 cosponsor) HR 1887, Disclosing Foreign Influence in Lobbying Act (Rep. Neguse, 1 cosponsor) HR 1908, End Congressional Stock Trading Act (Rep. Burchett, 1 cosponsor) HR 2180, Keep the Watchdogs Running Act (Rep. Connolly, 10 cosponsors) HR 2181, Protect Our Watchdogs Act (Rep. Connolly, 25 cosponsors) HR 2361, Cameras in the Courtroom Act (Rep. Connolly, no cosponsors) HR 2593, MARALAGO Act (Rep. Cohen, no cosponsors) HR 2624, HUMBLE Act (Rep. Craig, 1 cosponsor) HR 2675, Protecting Our Courts from Foreign Manipulation Act (Rep. Cline, no cosponsors) HR 2737, ELON MUSK Act (Rep. Pocan, 14 cosponsors) HR 2857, Drain the Swamp Act (Rep. Khanna, 3 cosponsors) HR 2795, End Judge Shopping Act (Rep. Sherrill, no cosponsors) HR 3182, Transparency in Representation through Uniform Stock Trading Ban (TRUST) Act (Rep. Bresnahan, no cosponsors) HR 3229, Foreign Agents Transparency Act (Rep. Cline, 6 cosponsors) HR 3388, Preventing Elected Leaders from Owning Securities and Investments (Rep. Alford, 1 cosponsor) HR 3513, Supreme Court Ethics, Recusal, and Transparency Act (Rep. Hank Johnson, 32 cosponsors) HR 3544, Supreme Court Tenure Establishment and Retirement Modernization (TERM) Act (Rep. Hank Johnson, 47 cosponsors) HR 3554, Close the Revolving Door Act (Rep. Neguse, no cosponsors) HR 3573, Stop TRUMP in Crypto Act (Rep. Waters, 15 cosponsors) HR 3635, Foreign Adversary Investment Prohibition Act (Rep. Kean, 1 cosponsor) HR 3680, No Corporate Crooks Act (Rep. Deluzio, 5 cosponsors) HR 3776, Don't Settle for Bribes Act (Rep. Magaziner, 4 cosponsors) HR 3779, STOCK Act 2.0 (Rep. Dave Min, 9 cosponsors) HR 4036, No Shorting America Act (Rep. Kean, 1 cosponsor) S 588, Presidential Tax Transparency Act (Sen. Wyden, 8 cosponsors) S 806, Hatch Act Enforcement Transparency and Accountability Act (Sen. Lujan, 1 cosponsor) S 856, Disclosing Foreign Influence in Lobbying Act (Sen. Grassley, 5 cosponsors) S 865, Lobbying Disclosure Improvement Act (Sen. Peters, 1 cosponsor) S 981, Foreign Agents Transparency Act (Sen. Grassley, 3 cosponsors) S 1133, Sunshine in the Courtroom Act (Sen. Grassley, 5 cosponsors) S 1146, Cameras in the Courtroom Act (Sen. Durbin, 4 cosponsors) S 1196, Special Government Employees Transparency Act (Sen. Lujan, 7 cosponsors) S 1365, No Federal Payments to Companies Controlled by Special Government Employees Act (Sen. Shaheen, no cosponsors) S 1498, Preventing Elected Leaders from Owning Securities and Investments Act (Sen. Hawley, 1 cosponsor) S 1668, End Crypto Corruption Act (Sen. Merkley, 21 cosponsors) S 1803, STABLE GENIUS Act (Sen. Bennet, no cosponsors) S 1814, Supreme Court Ethics, Recusal, and Transparency Act (Sen. Whitehouse, 26 cosponsors) S 1850, Close the Revolving Door Act (Sen. Bennet, no cosponsors) S 1873, MARSHALS Act (Sen. Booker, 4 cosponsors) S 2132, a bill to amend title 18, United States Code, to prevent and mitigate the potential for conflicts of interest following government service (Sen. Cornyn, 3 cosponsors) --Voting & Fair Representation Bills in the 119th Congress-- - **HR 3776**, Don't Settle for Bribes Act of 2025 (Rep. Magaziner (RI-02), 1 cosponsor) - To restrict the President from initiating civil lawsuits regarding any civil matters arising during their presidency until after leaving office - **HR 4908**, Time Off to Vote Act (Rep. Williams (GA-05) / Hirono (HI), 52 cosponsors) - To provide employees with a minimum of 2 consecutive hours of paid leave in order to vote in Federal elections - **HR 4917**, Expanding the VOTE Act / Expanding the Voluntary Opportunities for Translations in Elections Act (Rep. Williams (GA-05), multiple cosponsors) - To modify certain notice requirements, reduce threshold requirements for language assistance under the Voting Rights Act, study certain election requirements, clarify certain election requirements - **HR 4910**, Sustaining Our Democracy Act (Rep. Williams (GA-05), multiple cosponsors) - To establish a democracy advancement and innovation program to promote innovation to improve efficiency and smooth functioning in the administration of elections for Federal office - **HR 4909**, Voters on the Move Registration Act of 2025 (Rep. Williams (GA-05), 45 cosponsors) - To protect voter registration for individuals who have changed residences and ensure portability of voter registration across jurisdictions - **HR 4914**, Unhoused Voter Opportunity Through Elections Act (Rep. Williams (GA-05), 48 cosponsors) - To ensure that unhoused individuals can exercise their right to vote by removing barriers related to permanent address requirements - **HR 4915**, Election Mail Act (Rep. Williams (GA-05), no cosponsors) - To address issues related to election mail and ensure timely delivery of ballots and election materials through the postal service - **HR 4911**, POLL Act / People Over Long Lines Act (Rep. Williams (GA-05), multiple cosponsors) - To amend the Help America Vote Act of 2002 to ensure that voters in elections for Federal office do not wait in long lines in order to vote, establish standards for wait times at polling locations - **HR 4916**, Youth Voting Rights Act (Rep. Williams (GA-05), 44 cosponsors) - To expand youth access to voting through pre-registration of minors, on-campus polling locations, prohibition of certain residency requirements, and private right of action for age discrimination in voting - **HR 4912**, Help America Run Act (Rep. Williams (GA-05), 41 cosponsors) - To support Americans running for elected office by providing resources, reducing barriers to candidacy, and promoting diverse representation in government - **HR 4913**, CHALLENGES Act / Countering Harassment and Applying Legal Liability to Effectively Nurture Government Election Stability Act (Rep. Williams (GA-05), 33 cosponsors) - To amend the National Voter Registration Act of 1993 to protect individuals who are lawfully registered to vote from bad faith challenges to their registration status, requires clear and convincing evidence for challenges, establishes penalties --Anti-Corruption & Accountability Bills in the 119th Congress-- - **HR 3454**, Protecting Our Constitution and Communities Act (Rep. Landsman (OH-01), 11 cosponsors) - To amend the Congressional Budget and Impoundment Control Act of 1974 to provide a private right of action with respect to violations of such Act, strengthen Government Accountability Office enforcement - **H.J.Res. 54** (118th Congress), We the People Amendment (Rep. Jayapal (WA-07), 216 cosponsors in 118th Congress, reintroduced in 119th) - Proposing an amendment to the Constitution of the United States providing that the rights protected and extended by the Constitution are the rights of natural persons only, ending corporate constitutional rights and reversing Citizens United - **HR 1118** (118th Congress), DISCLOSE Act / Democracy Is Strengthened by Casting Light On Spending in Elections Act (Rep. Cicilline/Pappas, multiple cosponsors) - To require disclosure of political spending and eliminate dark money in elections - **HR 5048** (118th Congress), Protecting Our Democracy Act (Rep. Schiff, 186 cosponsors) - Comprehensive reforms to prevent presidential abuses of power and restore checks and balances - **HR 5106** (119th Congress), Restore Trust in Congress Act (Rep. Roy (R-TX) + Rep. Magaziner (D-RI), bipartisan with approximately 100 cosponsors) - To ban congressional stock trading and address conflicts of interest - **S. 3191** (119th Congress), Stop Ballroom Bribery Act (Sen. Warren, cosponsors: Sen. Blumenthal, Sen. Markey lead, Sen. Booker, Sen. Hirono, Sen. Merkley) - To prevent corruption by prohibiting federal officials from soliciting or accepting donations for White House construction or improvements from private entities while in office - **HR 6085** (119th Congress), Stop Ballroom Bribery Act (Rep. Garcia, cosponsors: Reps Summer Lee, Ayanna Pressley, Pramila Jayapal) - House companion bill to prevent corruption involving Trump ballroom donations by prohibiting White House construction donations from private entities while president is in office H.R.6356 (119th Congress), Artificial Intelligence (AI) Civil Rights Act (Rep. Yvette Clarke) - To establish civil rights protections for algorithmic decision‑making systems by prohibiting discriminatory AI uses in key areas of life, requiring robust pre‑ and post‑deployment testing for bias, and increasing transparency and accountability for high‑risk AI tools. S. 5315 (117th Congress), Anti-Corruption and Public Integrity Act (Sen. Warren; Rep. Jayapal) - To overhaul federal ethics and anti‑corruption rules by locking the revolving door, ending lobbying as currently structured, restricting stock trading and corporate board service by senior officials, establishing an independent anti‑corruption agency, strengthening judicial ethics standards, and reforming campaign finance laws to curb the influence of big and dark money in politics. S. ____ ( )Financial Disclosure Modernization Act (Sen. Schiff) - To strengthen personal financial disclosure requirements for senior federal officials by modernizing and expanding reporting categories for large assets and income, improving electronic filing and public access, and enhancing transparency to help ensure that public officials act in the public interest rather than their own financial interests. S.4822 (117th Congress) DISCLOSE Act (Sen. Whitehouse) - To increase transparency in federal elections by requiring groups that spend significant sums on campaign‑related communications to disclose their major donors, thereby limiting the ability of dark money organizations to secretly influence federal elections and policymaking. 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Roy) - aims to ensure only U.S. citizens vote in federal elections. It mandates that states require documentary proof of U.S. citizenship for voter registration and imposes a photo ID requirement for voting in federal elections. H.Con.Res.38 - Directing the President pursuant to section 5(c) of the War Powers Resolution to remove United States Armed Forces from unauthorized hostilities in the Islamic Republic of Iran. (Rep. Massie). S.J.Res.104 - A joint resolution to direct the removal of United States Armed Forces from hostilities within or against the Islamic Republic of Iran that have not been authorized by Congress. (Sen. Tim Kaine). H.R.7147 - Further Additional Continuing Appropriations Act, 2026 (Rep. Tom Cole). H.R.7744 - Department of Homeland Security Appropriations Act, 2026 (Rep. 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The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. Legitimate Bank Service Charges and Fees are Not Hidden, Exploitive and Junk Fees and Necessary Consumer Financial Responsibility There have been misguided characterizations that community bank service charges and fees are exploitive, unfair and even unlawful. What some have disparaging called Junk fees are bank fees and service charges that are justified, disclosed, and accepted by the consumers who utilize bank products and services. CBAI does not support practices that abuse consumers, but policymakers must accept the position that it is the consumers responsibility to maintain a positive deposit account balance and make their debt payments in a timely manner. It is wrong for policymakers to excuse irresponsible consumer financial behavior and doing so may encourage unacceptable behavior. Realistic Perspective on Financial Inclusion CBAI strongly supports financial inclusion and believes every responsible and able consumer and business should have a banking relationship with their local community bank. There is indisputable proof that the banking industry excels at serving the banking needs of American households. CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the role of federal, state or governments to provide banking services. Governments can assist the private sector in financial inclusion through incentives to promote community banks offering basic accounts and small-dollar consumer loans, especially to low- and middle-income consumers, which are those most likely to be unbanked or underbanked. Protecting Consumers by Restricting the Sale of Mortgage Trigger Leads Trigger leads are generated by credit reporting agencies that contact information about consumers applying for residential mortgage loans to mortgage marketers. This practice is permitted but restricted. Our members report that many of these marketing communications fall short of the legal requirements. Trigger leads compromise consumer privacy, create a flood of unwanted (even harassing) solicitations, create confusion and result in complaints. CBAI supports legislation that would restrict credit reporting agencies from selling consumer contact information unless the applicant has opted in to receive these solicitations. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks SBA Direct Lending Community banks and the SBA have a long, beneficial and cooperative private sector/public sector relationship and the SBA has historically not competed with banks in lending to businesses. Community banks are far superior in prudently underwriting and administering commercial lending relationships. The SBA originating and disbursing 7(a) loans will result in credit underwriting lapses which will put billions of taxpayer dollars at risk of loss. CBAI urges policymakers to prohibit the SBA from making direct 7(a) loans or otherwise expanding the institutions beyond well-regulated banks that could originate SBA loans. Postal Banking CBAI believes postal banking is misguided and views any entry by the USPS into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the USPS to develop and offer banking services. Public Banking CBAI believes public banking is misguided and views any entry by federal, state or local governments into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the government to offer banking services. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Small Business Data Collection A Final Rule was published in March of 2023. The Final Rule was flawed because it exempted too few financial institutions and set the revenue threshold so high that it now encompasses too many businesses, in addition to raising privacy and other concerns. There have been legal challenges to the Final Rule. CBAI supports the reasonable implementation of this reporting requirement and opposed efforts by Farm Credit to exempt its lenders. Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Reporting Beneficial Ownership Information CBAI supports shifting the burden of collecting the BOI of community bank accountholders to the Financial Crimes Enforcement Network (FinCEN). The current requirement is flawed because it does not relieve community banks from this burden. There have been legal challenges to the reporting requirements. CBAI supports making FinCEN the sole repository of BOI and relieving community banks from this burden. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Closing the Industrial Loan Company (ILC) Regulatory Loophole CBAI has consistently supported the long-standing American policy of prohibiting the mixing of banking and commerce, which ILCs represent, because of the risks they pose to the financial system, the FDICs DIF, our economy, consumers and American taxpayers. The risk posed by ILCs, particularly large technology and ecommerce giants, is a regulatory loophole that allows their holding companies to escape from consolidated federal supervision and regulation. This loophole must be closed. Appropriate Regulation of Fintechs and Innovations in Financial Services The pace of innovation in financial services has been accelerating. Many of these new services are offered by financial technology companies - better known as fintechs. Financial innovation presents community banks with challenges and opportunities. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose unreasonable requirements on them, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. Prescriptive and Intrusive FDIC Corporate Governance Guidelines In 2023, the FDIC proposed new corporate governance and risk management guidelines. Although the guidelines only apply to covered institutions with $10 billion or more in assets, these overly prescriptive guidelines apply the same set of standards to larger community banks as they do to the nations largest banks. These guidelines would make it even more difficult to attract new directors, particularly those in rural areas. Harmful Climate Risk Regulations Community bankers high-contact and relationship-based lending model ensures that controls are in place to monitor climate risks on an ongoing basis. CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Consumer Financial Protection Bureau (CFPB) Reform and Exemptions for Community Banks CFPBs regulations must provide community banks with the flexibility to meet the needs of their customers - not a one-size-fits-all approach. They must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. In reforming the CFPB, the single director governance should be replaced by a five-member board or commission. A broader definition of firms that grant credit should be subject to the CFPB rules, and they should be robustly supervised and examined. The focus of any enhanced regulation of financial products should be on the largest banks and financial firms, the unregulated shadow financial industry, and fintechs - not community banks. De Novo Community Bank Formation, the Dual Banking System, and Charter Choice The chartering of many newly chartered (de novo) community banks is vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of continued banking industry consolidation. Hand in hand with renewed de novo bank formation is the importance of maintaining the dual banking system, where chartering and supervision are divided between the federal government and the states, and where the federal government supervision and regulation is divided between the Federal Reserve, Office of Comptroller of the Currency, and the Federal Deposit Insurance Corporation. Community banks should be able to choose the banking charter and associated prudential regulator that best fits their unique needs and business model. Sound Principles for Housing Government Sponsored Entity (GSE) Reform Reforms in government support for housing finance remain important to the future of the housing market and the U.S. economy. Unlike other private aggregators or investors, the GSEs have a mandate to serve all markets at all times, which is critical to maintaining liquidity particularly when markets are experiencing financial stress and private capital moves to the sidelines. Exiting receivership includes building capital to successfully operate within a broader housing finance framework, and bipartisan agreement on the proper role of the housing GSEs and the programs necessary to fulfill reasonable and consistent housing goals. Responsible Bank Merger Activity Some community banks have found it helpful to merge with other community banks to be able to spread the significant and escalating costs of regulatory compliance, cybersecurity, technology and innovation to remain highly competitive. Restrictive bank merger legislation or regulations should not apply to community banks. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Insure) Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts Too-Big-To-Not-Insure The 2023 failures of Silicon Valley Bank and Signature Bank revealed that policymakers have created a new category of very large banks - Too-Big-To-Not-Insure (although they will fail) because the FDIC decided to insure 100% of the uninsured deposits of these two failed banks. There must be accountability by both the banks and the regulators for their respective failures. In the future, if systemically important financial institutions (SIFIs) cause losses to the DIF then SIFIs should be responsible for reimbursing the DIF for all the losses they created. Too-Big-To-Fail The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 1799 the Threshold Modernization Act (All Sections) regarding thresholds for currency transaction reporting and Suspicious Activity Reporting (SAR) (House) H.R. 7056 the Community Bank Tailoring Act (All Sections) regarding indexing various asset-based and bank-regulatory reporting thresholds o nominal GDP for community banks (House) H.R. 6955 the Main Street Capital Access Act (All Sections) regarding regulatory fairness, transparency and right-sizing; promoting healthy, growing, and competitive banking industry; and improving access o funding and capital for small to mid-sized banks (House) H.R. 6644 the Housing for the 21st Century Act (Title VI) regarding he inclusion of FDIC modernizing insurance and reciprocal deposit rules, targeted regulatory and examination relief, lowering compliance costs, encouraging the formation of new community banks, and strengthen Minority Depository Institutions (MDIs) (House and Senate) S. 2651 or the ROAD Act which is the 21st Century ROAD to Housing Act regarding the inclusion of the provisions in H.R. 6644 (Housing for the 21st Century Act (Title VI) (House and Senate) H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Letters - Comment Letter to the FDIC regarding PayPal Holdings, Inc. application to the FDIC for deposit insurance for PayPal Bank (FDIC) Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71 (IRS) Comment Letter to the OCC, FDIC and Federal Reserve regarding Notice of Proposed Rulemaking: Regulatory Capital Rule: Revisions to the Community Bank Leverage Ratio Framework - Docket ID OCC-2025-0141, Federal Reserve Docket No. R-1876 and RIN 7100-AH08, and FDIC RIN 3064-AG17 (OCC, FDIC and Federal Reserve) Comment Letter to the Federal Reserve regarding Request for Information and Comment on Reserve Board Payment Account Prototype - Docket No. OP-1877 (aka Fed skinny payment accounts) (Federal Reserve) Comment Letter to the Federal Reserve regarding Request for Information and Comments on the Future of the Federal Reserve Banks Check Services - Docket No. OP-1874 (Federal Reserve) Comment Letter to the OCC regarding Notice of Proposed Rulemaking: Revised Guidelines - OCC Guidelines Establishing Heightened Standards for Certain Large Insured National Banks, Insured Federal Savings Associations, and Insured Federal Branches; Technical Amendments - Docket ID OCC-2025-0207 (OCC) Action Alerts - Action Alert - Urge Your Representative to Support Community Bank Regulatory Relief (House) (See H.R. 6644 Housing for the 21st Century Act above) Miscellaneous - Potential House field hearing on financial fraud (House) Approval of application for Kraken master account with the Federal Reserve (House) EGRPRA Outreach Meeting presentation on March 26, 2026, regarding de novos, particularly newly chartered community banks (OCC, FDIC, Federal Reserve)","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":54,"name":"Federal Deposit Insurance Corporation (FDIC)"},{"id":62,"name":"Federal Reserve System"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":183,"name":"Office of the Comptroller of the Currency (OCC)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"FIN","general_issue_code_display":"Financial Institutions/Investments/Securities","description":"CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. Legitimate Bank Service Charges and Fees are Not Hidden, Exploitive and Junk Fees and Necessary Consumer Financial Responsibility There have been misguided characterizations that community bank service charges and fees are exploitive, unfair and even unlawful. What some have disparaging called Junk fees are bank fees and service charges that are justified, disclosed, and accepted by the consumers who utilize bank products and services. CBAI does not support practices that abuse consumers, but policymakers must accept the position that it is the consumers responsibility to maintain a positive deposit account balance and make their debt payments in a timely manner. It is wrong for policymakers to excuse irresponsible consumer financial behavior and doing so may encourage unacceptable behavior. Realistic Perspective on Financial Inclusion CBAI strongly supports financial inclusion and believes every responsible and able consumer and business should have a banking relationship with their local community bank. There is indisputable proof that the banking industry excels at serving the banking needs of American households. CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the role of federal, state or governments to provide banking services. Governments can assist the private sector in financial inclusion through incentives to promote community banks offering basic accounts and small-dollar consumer loans, especially to low- and middle-income consumers, which are those most likely to be unbanked or underbanked. Protecting Consumers by Restricting the Sale of Mortgage Trigger Leads Trigger leads are generated by credit reporting agencies that contact information about consumers applying for residential mortgage loans to mortgage marketers. This practice is permitted but restricted. Our members report that many of these marketing communications fall short of the legal requirements. Trigger leads compromise consumer privacy, create a flood of unwanted (even harassing) solicitations, create confusion and result in complaints. CBAI supports legislation that would restrict credit reporting agencies from selling consumer contact information unless the applicant has opted in to receive these solicitations. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks SBA Direct Lending Community banks and the SBA have a long, beneficial and cooperative private sector/public sector relationship and the SBA has historically not competed with banks in lending to businesses. Community banks are far superior in prudently underwriting and administering commercial lending relationships. The SBA originating and disbursing 7(a) loans will result in credit underwriting lapses which will put billions of taxpayer dollars at risk of loss. CBAI urges policymakers to prohibit the SBA from making direct 7(a) loans or otherwise expanding the institutions beyond well-regulated banks that could originate SBA loans. Postal Banking CBAI believes postal banking is misguided and views any entry by the USPS into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the USPS to develop and offer banking services. Public Banking CBAI believes public banking is misguided and views any entry by federal, state or local governments into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the government to offer banking services. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Small Business Data Collection A Final Rule was published in March of 2023. The Final Rule was flawed because it exempted too few financial institutions and set the revenue threshold so high that it now encompasses too many businesses, in addition to raising privacy and other concerns. There have been legal challenges to the Final Rule. CBAI supports the reasonable implementation of this reporting requirement and opposed efforts by Farm Credit to exempt its lenders. Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Reporting Beneficial Ownership Information CBAI supports shifting the burden of collecting the BOI of community bank accountholders to the Financial Crimes Enforcement Network (FinCEN). The current requirement is flawed because it does not relieve community banks from this burden. There have been legal challenges to the reporting requirements. CBAI supports making FinCEN the sole repository of BOI and relieving community banks from this burden. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Closing the Industrial Loan Company (ILC) Regulatory Loophole CBAI has consistently supported the long-standing American policy of prohibiting the mixing of banking and commerce, which ILCs represent, because of the risks they pose to the financial system, the FDICs DIF, our economy, consumers and American taxpayers. The risk posed by ILCs, particularly large technology and ecommerce giants, is a regulatory loophole that allows their holding companies to escape from consolidated federal supervision and regulation. This loophole must be closed. Appropriate Regulation of Fintechs and Innovations in Financial Services The pace of innovation in financial services has been accelerating. Many of these new services are offered by financial technology companies - better known as fintechs. Financial innovation presents community banks with challenges and opportunities. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose unreasonable requirements on them, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. Prescriptive and Intrusive FDIC Corporate Governance Guidelines In 2023, the FDIC proposed new corporate governance and risk management guidelines. Although the guidelines only apply to covered institutions with $10 billion or more in assets, these overly prescriptive guidelines apply the same set of standards to larger community banks as they do to the nations largest banks. These guidelines would make it even more difficult to attract new directors, particularly those in rural areas. Harmful Climate Risk Regulations Community bankers high-contact and relationship-based lending model ensures that controls are in place to monitor climate risks on an ongoing basis. CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Consumer Financial Protection Bureau (CFPB) Reform and Exemptions for Community Banks CFPBs regulations must provide community banks with the flexibility to meet the needs of their customers - not a one-size-fits-all approach. They must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. In reforming the CFPB, the single director governance should be replaced by a five-member board or commission. A broader definition of firms that grant credit should be subject to the CFPB rules, and they should be robustly supervised and examined. The focus of any enhanced regulation of financial products should be on the largest banks and financial firms, the unregulated shadow financial industry, and fintechs - not community banks. De Novo Community Bank Formation, the Dual Banking System, and Charter Choice The chartering of many newly chartered (de novo) community banks is vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of continued banking industry consolidation. Hand in hand with renewed de novo bank formation is the importance of maintaining the dual banking system, where chartering and supervision are divided between the federal government and the states, and where the federal government supervision and regulation is divided between the Federal Reserve, Office of Comptroller of the Currency, and the Federal Deposit Insurance Corporation. Community banks should be able to choose the banking charter and associated prudential regulator that best fits their unique needs and business model. Sound Principles for Housing Government Sponsored Entity (GSE) Reform Reforms in government support for housing finance remain important to the future of the housing market and the U.S. economy. Unlike other private aggregators or investors, the GSEs have a mandate to serve all markets at all times, which is critical to maintaining liquidity particularly when markets are experiencing financial stress and private capital moves to the sidelines. Exiting receivership includes building capital to successfully operate within a broader housing finance framework, and bipartisan agreement on the proper role of the housing GSEs and the programs necessary to fulfill reasonable and consistent housing goals. Responsible Bank Merger Activity Some community banks have found it helpful to merge with other community banks to be able to spread the significant and escalating costs of regulatory compliance, cybersecurity, technology and innovation to remain highly competitive. Restrictive bank merger legislation or regulations should not apply to community banks. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Insure) Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts Too-Big-To-Not-Insure The 2023 failures of Silicon Valley Bank and Signature Bank revealed that policymakers have created a new category of very large banks - Too-Big-To-Not-Insure (although they will fail) because the FDIC decided to insure 100% of the uninsured deposits of these two failed banks. There must be accountability by both the banks and the regulators for their respective failures. In the future, if systemically important financial institutions (SIFIs) cause losses to the DIF then SIFIs should be responsible for reimbursing the DIF for all the losses they created. Too-Big-To-Fail The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 1799 the Threshold Modernization Act (All Sections) regarding thresholds for currency transaction reporting and Suspicious Activity Reporting (SAR) (House) H.R. 7056 the Community Bank Tailoring Act (All Sections) regarding indexing various asset-based and bank-regulatory reporting thresholds o nominal GDP for community banks (House) H.R. 6955 the Main Street Capital Access Act (All Sections) regarding regulatory fairness, transparency and right-sizing; promoting healthy, growing, and competitive banking industry; and improving access o funding and capital for small to mid-sized banks (House) H.R. 6644 the Housing for the 21st Century Act (Title VI) regarding he inclusion of FDIC modernizing insurance and reciprocal deposit rules, targeted regulatory and examination relief, lowering compliance costs, encouraging the formation of new community banks, and strengthen Minority Depository Institutions (MDIs) (House and Senate) S. 2651 or the ROAD Act which is the 21st Century ROAD to Housing Act regarding the inclusion of the provisions in H.R. 6644 (Housing for the 21st Century Act (Title VI) (House and Senate) H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Letters - Comment Letter to the FDIC regarding PayPal Holdings, Inc. application to the FDIC for deposit insurance for PayPal Bank (FDIC) Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71 (IRS) Comment Letter to the OCC, FDIC and Federal Reserve regarding Notice of Proposed Rulemaking: Regulatory Capital Rule: Revisions to the Community Bank Leverage Ratio Framework - Docket ID OCC-2025-0141, Federal Reserve Docket No. R-1876 and RIN 7100-AH08, and FDIC RIN 3064-AG17 (OCC, FDIC and Federal Reserve) Comment Letter to the Federal Reserve regarding Request for Information and Comment on Reserve Board Payment Account Prototype - Docket No. OP-1877 (aka Fed skinny payment accounts) (Federal Reserve) Comment Letter to the Federal Reserve regarding Request for Information and Comments on the Future of the Federal Reserve Banks Check Services - Docket No. OP-1874 (Federal Reserve) Comment Letter to the OCC regarding Notice of Proposed Rulemaking: Revised Guidelines - OCC Guidelines Establishing Heightened Standards for Certain Large Insured National Banks, Insured Federal Savings Associations, and Insured Federal Branches; Technical Amendments - Docket ID OCC-2025-0207 (OCC) Action Alerts - Action Alert - Urge Your Representative to Support Community Bank Regulatory Relief (House) (See H.R. 6644 Housing for the 21st Century Act above) Miscellaneous - Potential House field hearing on financial fraud (House) Approval of application for Kraken master account with the Federal Reserve (House) EGRPRA Outreach Meeting presentation on March 26, 2026, regarding de novos, particularly newly chartered community banks (OCC, FDIC, Federal Reserve)","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":54,"name":"Federal Deposit Insurance Corporation (FDIC)"},{"id":62,"name":"Federal Reserve System"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":183,"name":"Office of the Comptroller of the Currency (OCC)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"AGR","general_issue_code_display":"Agriculture","description":"CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Small Business Data Collection A Final Rule was published in March of 2023. The Final Rule was flawed because it exempted too few financial institutions and set the revenue threshold so high that it now encompasses too many businesses, in addition to raising privacy and other concerns. There have been legal challenges to the Final Rule. CBAI supports the reasonable implementation of this reporting requirement and opposed efforts by Farm Credit to exempt its lenders. Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Reporting Beneficial Ownership Information CBAI supports shifting the burden of collecting the BOI of community bank accountholders to the Financial Crimes Enforcement Network (FinCEN). The current requirement is flawed because it does not relieve community banks from this burden. There have been legal challenges to the reporting requirements. CBAI supports making FinCEN the sole repository of BOI and relieving community banks from this burden. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Harmful Climate Risk Regulations Community bankers high-contact and relationship-based lending model ensures that controls are in place to monitor climate risks on an ongoing basis. CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Sound Principles for Housing Government Sponsored Entity (GSE) Reform Reforms in government support for housing finance remain important to the future of the housing market and the U.S. economy. Unlike other private aggregators or investors, the GSEs have a mandate to serve all markets at all times, which is critical to maintaining liquidity particularly when markets are experiencing financial stress and private capital moves to the sidelines. Exiting receivership includes building capital to successfully operate within a broader housing finance framework, and bipartisan agreement on the proper role of the housing GSEs and the programs necessary to fulfill reasonable and consistent housing goals. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 6644 the Housing for the 21st Century Act (Title VI) regarding he inclusion of FDIC modernizing insurance and reciprocal deposit rules, targeted regulatory and examination relief, lowering compliance costs, encouraging the formation of new community banks, and strengthen Minority Depository Institutions (MDIs) (House) S. 2651 or the ROAD Act which is the 21st Century ROAD to Housing Act regarding the inclusion of the provisions in H.R. 6644 (Housing for the 21st Century Act (Title VI) (House and Senate) H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Letters - Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71 (IRS) Comment Letter to the Federal Reserve regarding Request for Information and Comments on the Future of the Federal Reserve Banks Check Services - Docket No. OP-1874 (Federal Reserve) Action Alerts - None Miscellaneous - Potential House field hearing on financial fraud (House)","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":62,"name":"Federal Reserve System"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"CSP","general_issue_code_display":"Consumer Issues/Safety/Products","description":"CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Legitimate Bank Service Charges and Fees are Not Hidden, Exploitive and Junk Fees and Necessary Consumer Financial Responsibility There have been misguided characterizations that community bank service charges and fees are exploitive, unfair and even unlawful. What some have disparaging called Junk fees are bank fees and service charges that are justified, disclosed, and accepted by the consumers who utilize bank products and services. CBAI does not support practices that abuse consumers, but policymakers must accept the position that it is the consumers responsibility to maintain a positive deposit account balance and make their debt payments in a timely manner. It is wrong for policymakers to excuse irresponsible consumer financial behavior and doing so may encourage unacceptable behavior. Realistic Perspective on Financial Inclusion CBAI strongly supports financial inclusion and believes every responsible and able consumer and business should have a banking relationship with their local community bank. There is indisputable proof that the banking industry excels at serving the banking needs of American households. CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the role of federal, state or governments to provide banking services. Governments can assist the private sector in financial inclusion through incentives to promote community banks offering basic accounts and small-dollar consumer loans, especially to low- and middle-income consumers, which are those most likely to be unbanked or underbanked. Protecting Consumers by Restricting the Sale of Mortgage Trigger Leads Trigger leads are generated by credit reporting agencies that contact information about consumers applying for residential mortgage loans to mortgage marketers. This practice is permitted but restricted. Our members report that many of these marketing communications fall short of the legal requirements. Trigger leads compromise consumer privacy, create a flood of unwanted (even harassing) solicitations, create confusion and result in complaints. CBAI supports legislation that would restrict credit reporting agencies from selling consumer contact information unless the applicant has opted in to receive these solicitations. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks Postal Banking CBAI believes postal banking is misguided and views any entry by the USPS into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the USPS to develop and offer banking services. Public Banking CBAI believes public banking is misguided and views any entry by federal, state or local governments into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the government to offer banking services. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Closing the Industrial Loan Company (ILC) Regulatory Loophole CBAI has consistently supported the long-standing American policy of prohibiting the mixing of banking and commerce, which ILCs represent, because of the risks they pose to the financial system, the FDICs DIF, our economy, consumers and American taxpayers. The risk posed by ILCs, particularly large technology and ecommerce giants, is a regulatory loophole that allows their holding companies to escape from consolidated federal supervision and regulation. This loophole must be closed. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Consumer Financial Protection Bureau (CFPB) Reform and Exemptions for Community Banks CFPBs regulations must provide community banks with the flexibility to meet the needs of their customers - not a one-size-fits-all approach. They must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. In reforming the CFPB, the single director governance should be replaced by a five-member board or commission. A broader definition of firms that grant credit should be subject to the CFPB rules, and they should be robustly supervised and examined. The focus of any enhanced regulation of financial products should be on the largest banks and financial firms, the unregulated shadow financial industry, and fintechs - not community banks. Sound Principles for Housing Government Sponsored Entity (GSE) Reform Reforms in government support for housing finance remain important to the future of the housing market and the U.S. economy. Unlike other private aggregators or investors, the GSEs have a mandate to serve all markets at all times, which is critical to maintaining liquidity particularly when markets are experiencing financial stress and private capital moves to the sidelines. Exiting receivership includes building capital to successfully operate within a broader housing finance framework, and bipartisan agreement on the proper role of the housing GSEs and the programs necessary to fulfill reasonable and consistent housing goals. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Letters - Comment Letter to the FDIC regarding PayPal Holdings, Inc. application to the FDIC for deposit insurance for PayPal Bank (FDIC) Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71 (IRS) Comment Letter to the Federal Reserve regarding Request for Information and Comments on the Future of the Federal Reserve Banks Check Services - Docket No. OP-1874 (Federal Reserve) Action Alerts - None Miscellaneous - Potential House field hearing on financial fraud (House) Approval of application for Kraken master account with the Federal Reserve (House)","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":54,"name":"Federal Deposit Insurance Corporation (FDIC)"},{"id":62,"name":"Federal Reserve System"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"SMB","general_issue_code_display":"Small Business","description":"CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks SBA Direct Lending Community banks and the SBA have a long, beneficial and cooperative private sector/public sector relationship and the SBA has historically not competed with banks in lending to businesses. Community banks are far superior in prudently underwriting and administering commercial lending relationships. The SBA originating and disbursing 7(a) loans will result in credit underwriting lapses which will put billions of taxpayer dollars at risk of loss. CBAI urges policymakers to prohibit the SBA from making direct 7(a) loans or otherwise expanding the institutions beyond well-regulated banks that could originate SBA loans. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Small Business Data Collection A Final Rule was published in March of 2023. The Final Rule was flawed because it exempted too few financial institutions and set the revenue threshold so high that it now encompasses too many businesses, in addition to raising privacy and other concerns. There have been legal challenges to the Final Rule. CBAI supports the reasonable implementation of this reporting requirement and opposed efforts by Farm Credit to exempt its lenders. Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Reporting Beneficial Ownership Information CBAI supports shifting the burden of collecting the BOI of community bank accountholders to the Financial Crimes Enforcement Network (FinCEN). The current requirement is flawed because it does not relieve community banks from this burden. There have been legal challenges to the reporting requirements. CBAI supports making FinCEN the sole repository of BOI and relieving community banks from this burden. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Harmful Climate Risk Regulations Community bankers high-contact and relationship-based lending model ensures that controls are in place to monitor climate risks on an ongoing basis. CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Consumer Financial Protection Bureau (CFPB) Reform and Exemptions for Community Banks CFPBs regulations must provide community banks with the flexibility to meet the needs of their customers - not a one-size-fits-all approach. They must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. In reforming the CFPB, the single director governance should be replaced by a five-member board or commission. A broader definition of firms that grant credit should be subject to the CFPB rules, and they should be robustly supervised and examined. The focus of any enhanced regulation of financial products should be on the largest banks and financial firms, the unregulated shadow financial industry, and fintechs - not community banks. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Action Alerts - None Letters - Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71 (IRS) Comment Letter to the Federal Reserve regarding Request for Information and Comments on the Future of the Federal Reserve Banks Check Services - Docket No. OP-1874 (Federal Reserve) Miscellaneous - Potential House field hearing on financial fraud (House)","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":62,"name":"Federal Reserve System"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"TAX","general_issue_code_display":"Taxation/Internal Revenue Code","description":"CBAI Federal Policy Priorities - Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Letters - Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71(IRS) Action Alerts - None Miscellaneous - None","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"ECN","general_issue_code_display":"Economics/Economic Development","description":"CBAI Federal Policy Priorities - Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 6644 the Housing for the 21st Century Act (Title VI) regarding the inclusion of FDIC modernizing insurance and reciprocal deposit rules, targeted regulatory and examination relief, lowering compliance costs, encouraging the formation of new community banks, and strengthen Minority Depository Institutions (MDIs) (House and Senate) S. 2651 or the ROAD Act which is the 21st Century ROAD to Housing Act regarding the inclusion of the provisions in H.R. 6644 (Housing for the 21st Century Act (Title VI) (House and Senate) H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Letters - Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71 (IRS) Comment Letter to the Federal Reserve regarding Request for Information and Comments on the Future of the Federal Reserve Banks Check Services - Docket No. OP-1874 (Federal Reserve) Action Alerts - Action Alert - Urge Your Representative to Support Community Bank Regulatory Relief (House) (See H.R. 6644 Housing for the 21st Century Act above) Miscellaneous - None","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":62,"name":"Federal Reserve System"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":1,"name":"SENATE"}]}],"conviction_disclosures":[],"foreign_entities":[],"affiliated_organizations":[]},{"url":"https://lda.gov/api/v1/filings/8c041376-c992-457a-94a7-eb83e0dd4f41/","filing_uuid":"8c041376-c992-457a-94a7-eb83e0dd4f41","filing_type":"Q1","filing_type_display":"1st Quarter - Report","filing_year":2026,"filing_period":"first_quarter","filing_period_display":"1st Quarter (Jan 1 - Mar 31)","filing_document_url":"https://lda.gov/filings/public/filing/8c041376-c992-457a-94a7-eb83e0dd4f41/print/","filing_document_content_type":"text/html","income":null,"expenses":"65000.00","expenses_method":"A","expenses_method_display":"A","posted_by_name":"David G Schroeder","dt_posted":"2026-04-10T15:38:54-04:00","termination_date":null,"registrant_country":"United States of America","registrant_ppb_country":null,"registrant_address_1":"901 Community Drive","registrant_address_2":null,"registrant_different_address":false,"registrant_city":"Springfield","registrant_state":"IL","registrant_zip":"62703","registrant":{"id":400531588,"url":"https://lda.gov/api/v1/registrants/400531588/","house_registrant_id":null,"name":"COMMUNITY BANKERS ASSOCIATION OF ILLINOIS","description":"Trade association representing Illinois' community banks and thrifts","address_1":"901 Community Drive","address_2":null,"address_3":null,"address_4":null,"city":"Springfield","state":"IL","state_display":"Illinois","zip":"62703","country":"US","country_display":"United States of America","ppb_country":"US","ppb_country_display":"United States of America","contact_name":"DAVID G. SCHROEDER","contact_telephone":"+1 847-909-8341","dt_updated":"2026-07-28T17:21:17.493355-04:00"},"client":{"id":192301,"url":"https://lda.gov/api/v1/clients/192301/","client_id":12,"name":"COMMUNITY BANKERS ASSOCIATION OF ILLINOIS","general_description":null,"client_government_entity":false,"client_self_select":true,"state":"IL","state_display":"Illinois","country":"US","country_display":"United States of America","ppb_state":"IL","ppb_state_display":"Illinois","ppb_country":"US","ppb_country_display":"United States of America","effective_date":"2010-01-01"},"lobbying_activities":[{"general_issue_code":"BAN","general_issue_code_display":"Banking","description":"CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. Legitimate Bank Service Charges and Fees are Not Hidden, Exploitive and Junk Fees and Necessary Consumer Financial Responsibility There have been misguided characterizations that community bank service charges and fees are exploitive, unfair and even unlawful. What some have disparaging called Junk fees are bank fees and service charges that are justified, disclosed, and accepted by the consumers who utilize bank products and services. CBAI does not support practices that abuse consumers, but policymakers must accept the position that it is the consumers responsibility to maintain a positive deposit account balance and make their debt payments in a timely manner. It is wrong for policymakers to excuse irresponsible consumer financial behavior and doing so may encourage unacceptable behavior. Realistic Perspective on Financial Inclusion CBAI strongly supports financial inclusion and believes every responsible and able consumer and business should have a banking relationship with their local community bank. There is indisputable proof that the banking industry excels at serving the banking needs of American households. CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the role of federal, state or governments to provide banking services. Governments can assist the private sector in financial inclusion through incentives to promote community banks offering basic accounts and small-dollar consumer loans, especially to low- and middle-income consumers, which are those most likely to be unbanked or underbanked. Protecting Consumers by Restricting the Sale of Mortgage Trigger Leads Trigger leads are generated by credit reporting agencies that contact information about consumers applying for residential mortgage loans to mortgage marketers. This practice is permitted but restricted. Our members report that many of these marketing communications fall short of the legal requirements. Trigger leads compromise consumer privacy, create a flood of unwanted (even harassing) solicitations, create confusion and result in complaints. CBAI supports legislation that would restrict credit reporting agencies from selling consumer contact information unless the applicant has opted in to receive these solicitations. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks SBA Direct Lending Community banks and the SBA have a long, beneficial and cooperative private sector/public sector relationship and the SBA has historically not competed with banks in lending to businesses. Community banks are far superior in prudently underwriting and administering commercial lending relationships. The SBA originating and disbursing 7(a) loans will result in credit underwriting lapses which will put billions of taxpayer dollars at risk of loss. CBAI urges policymakers to prohibit the SBA from making direct 7(a) loans or otherwise expanding the institutions beyond well-regulated banks that could originate SBA loans. Postal Banking CBAI believes postal banking is misguided and views any entry by the USPS into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the USPS to develop and offer banking services. Public Banking CBAI believes public banking is misguided and views any entry by federal, state or local governments into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the government to offer banking services. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Small Business Data Collection A Final Rule was published in March of 2023. The Final Rule was flawed because it exempted too few financial institutions and set the revenue threshold so high that it now encompasses too many businesses, in addition to raising privacy and other concerns. There have been legal challenges to the Final Rule. CBAI supports the reasonable implementation of this reporting requirement and opposed efforts by Farm Credit to exempt its lenders. Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Reporting Beneficial Ownership Information CBAI supports shifting the burden of collecting the BOI of community bank accountholders to the Financial Crimes Enforcement Network (FinCEN). The current requirement is flawed because it does not relieve community banks from this burden. There have been legal challenges to the reporting requirements. CBAI supports making FinCEN the sole repository of BOI and relieving community banks from this burden. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Closing the Industrial Loan Company (ILC) Regulatory Loophole CBAI has consistently supported the long-standing American policy of prohibiting the mixing of banking and commerce, which ILCs represent, because of the risks they pose to the financial system, the FDICs DIF, our economy, consumers and American taxpayers. The risk posed by ILCs, particularly large technology and ecommerce giants, is a regulatory loophole that allows their holding companies to escape from consolidated federal supervision and regulation. This loophole must be closed. Appropriate Regulation of Fintechs and Innovations in Financial Services The pace of innovation in financial services has been accelerating. Many of these new services are offered by financial technology companies - better known as fintechs. Financial innovation presents community banks with challenges and opportunities. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose unreasonable requirements on them, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. Prescriptive and Intrusive FDIC Corporate Governance Guidelines In 2023, the FDIC proposed new corporate governance and risk management guidelines. Although the guidelines only apply to covered institutions with $10 billion or more in assets, these overly prescriptive guidelines apply the same set of standards to larger community banks as they do to the nations largest banks. These guidelines would make it even more difficult to attract new directors, particularly those in rural areas. Harmful Climate Risk Regulations Community bankers high-contact and relationship-based lending model ensures that controls are in place to monitor climate risks on an ongoing basis. CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Consumer Financial Protection Bureau (CFPB) Reform and Exemptions for Community Banks CFPBs regulations must provide community banks with the flexibility to meet the needs of their customers - not a one-size-fits-all approach. They must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. In reforming the CFPB, the single director governance should be replaced by a five-member board or commission. A broader definition of firms that grant credit should be subject to the CFPB rules, and they should be robustly supervised and examined. The focus of any enhanced regulation of financial products should be on the largest banks and financial firms, the unregulated shadow financial industry, and fintechs - not community banks. De Novo Community Bank Formation, the Dual Banking System, and Charter Choice The chartering of many newly chartered (de novo) community banks is vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of continued banking industry consolidation. Hand in hand with renewed de novo bank formation is the importance of maintaining the dual banking system, where chartering and supervision are divided between the federal government and the states, and where the federal government supervision and regulation is divided between the Federal Reserve, Office of Comptroller of the Currency, and the Federal Deposit Insurance Corporation. Community banks should be able to choose the banking charter and associated prudential regulator that best fits their unique needs and business model. Sound Principles for Housing Government Sponsored Entity (GSE) Reform Reforms in government support for housing finance remain important to the future of the housing market and the U.S. economy. Unlike other private aggregators or investors, the GSEs have a mandate to serve all markets at all times, which is critical to maintaining liquidity particularly when markets are experiencing financial stress and private capital moves to the sidelines. Exiting receivership includes building capital to successfully operate within a broader housing finance framework, and bipartisan agreement on the proper role of the housing GSEs and the programs necessary to fulfill reasonable and consistent housing goals. Responsible Bank Merger Activity Some community banks have found it helpful to merge with other community banks to be able to spread the significant and escalating costs of regulatory compliance, cybersecurity, technology and innovation to remain highly competitive. Restrictive bank merger legislation or regulations should not apply to community banks. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Insure) Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts Too-Big-To-Not-Insure The 2023 failures of Silicon Valley Bank and Signature Bank revealed that policymakers have created a new category of very large banks - Too-Big-To-Not-Insure (although they will fail) because the FDIC decided to insure 100% of the uninsured deposits of these two failed banks. There must be accountability by both the banks and the regulators for their respective failures. In the future, if systemically important financial institutions (SIFIs) cause losses to the DIF then SIFIs should be responsible for reimbursing the DIF for all the losses they created. Too-Big-To-Fail The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 1799 the Threshold Modernization Act (All Sections) regarding thresholds for currency transaction reporting and Suspicious Activity Reporting (SAR) (House) H.R. 7056 the Community Bank Tailoring Act (All Sections) regarding indexing various asset-based and bank-regulatory reporting thresholds o nominal GDP for community banks (House) H.R. 6955 the Main Street Capital Access Act (All Sections) regarding regulatory fairness, transparency and right-sizing; promoting healthy, growing, and competitive banking industry; and improving access o funding and capital for small to mid-sized banks (House) H.R. 6644 the Housing for the 21st Century Act (Title VI) regarding he inclusion of FDIC modernizing insurance and reciprocal deposit rules, targeted regulatory and examination relief, lowering compliance costs, encouraging the formation of new community banks, and strengthen Minority Depository Institutions (MDIs) (House and Senate) S. 2651 or the ROAD Act which is the 21st Century ROAD to Housing Act regarding the inclusion of the provisions in H.R. 6644 (Housing for the 21st Century Act (Title VI) (House and Senate) H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Letters - Comment Letter to the FDIC regarding PayPal Holdings, Inc. application to the FDIC for deposit insurance for PayPal Bank (FDIC) Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71 (IRS) Comment Letter to the OCC, FDIC and Federal Reserve regarding Notice of Proposed Rulemaking: Regulatory Capital Rule: Revisions to the Community Bank Leverage Ratio Framework - Docket ID OCC-2025-0141, Federal Reserve Docket No. R-1876 and RIN 7100-AH08, and FDIC RIN 3064-AG17 (OCC, FDIC and Federal Reserve) Comment Letter to the Federal Reserve regarding Request for Information and Comment on Reserve Board Payment Account Prototype - Docket No. OP-1877 (aka Fed skinny payment accounts) (Federal Reserve) Comment Letter to the Federal Reserve regarding Request for Information and Comments on the Future of the Federal Reserve Banks Check Services - Docket No. OP-1874 (Federal Reserve) Comment Letter to the OCC regarding Notice of Proposed Rulemaking: Revised Guidelines - OCC Guidelines Establishing Heightened Standards for Certain Large Insured National Banks, Insured Federal Savings Associations, and Insured Federal Branches; Technical Amendments - Docket ID OCC-2025-0207 (OCC) Action Alerts - Action Alert - Urge Your Representative to Support Community Bank Regulatory Relief (House) (See H.R. 6644 Housing for the 21st Century Act above) Miscellaneous - Potential House field hearing on financial fraud (House) Approval of application for Kraken master account with the Federal Reserve (House) EGRPRA Outreach Meeting presentation on March 26, 2026, regarding de novos, particularly newly chartered community banks (OCC, FDIC, Federal Reserve)","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":54,"name":"Federal Deposit Insurance Corporation (FDIC)"},{"id":62,"name":"Federal Reserve System"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":183,"name":"Office of the Comptroller of the Currency (OCC)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"FIN","general_issue_code_display":"Financial Institutions/Investments/Securities","description":"CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. Legitimate Bank Service Charges and Fees are Not Hidden, Exploitive and Junk Fees and Necessary Consumer Financial Responsibility There have been misguided characterizations that community bank service charges and fees are exploitive, unfair and even unlawful. What some have disparaging called Junk fees are bank fees and service charges that are justified, disclosed, and accepted by the consumers who utilize bank products and services. CBAI does not support practices that abuse consumers, but policymakers must accept the position that it is the consumers responsibility to maintain a positive deposit account balance and make their debt payments in a timely manner. It is wrong for policymakers to excuse irresponsible consumer financial behavior and doing so may encourage unacceptable behavior. Realistic Perspective on Financial Inclusion CBAI strongly supports financial inclusion and believes every responsible and able consumer and business should have a banking relationship with their local community bank. There is indisputable proof that the banking industry excels at serving the banking needs of American households. CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the role of federal, state or governments to provide banking services. Governments can assist the private sector in financial inclusion through incentives to promote community banks offering basic accounts and small-dollar consumer loans, especially to low- and middle-income consumers, which are those most likely to be unbanked or underbanked. Protecting Consumers by Restricting the Sale of Mortgage Trigger Leads Trigger leads are generated by credit reporting agencies that contact information about consumers applying for residential mortgage loans to mortgage marketers. This practice is permitted but restricted. Our members report that many of these marketing communications fall short of the legal requirements. Trigger leads compromise consumer privacy, create a flood of unwanted (even harassing) solicitations, create confusion and result in complaints. CBAI supports legislation that would restrict credit reporting agencies from selling consumer contact information unless the applicant has opted in to receive these solicitations. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks SBA Direct Lending Community banks and the SBA have a long, beneficial and cooperative private sector/public sector relationship and the SBA has historically not competed with banks in lending to businesses. Community banks are far superior in prudently underwriting and administering commercial lending relationships. The SBA originating and disbursing 7(a) loans will result in credit underwriting lapses which will put billions of taxpayer dollars at risk of loss. CBAI urges policymakers to prohibit the SBA from making direct 7(a) loans or otherwise expanding the institutions beyond well-regulated banks that could originate SBA loans. Postal Banking CBAI believes postal banking is misguided and views any entry by the USPS into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the USPS to develop and offer banking services. Public Banking CBAI believes public banking is misguided and views any entry by federal, state or local governments into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the government to offer banking services. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Small Business Data Collection A Final Rule was published in March of 2023. The Final Rule was flawed because it exempted too few financial institutions and set the revenue threshold so high that it now encompasses too many businesses, in addition to raising privacy and other concerns. There have been legal challenges to the Final Rule. CBAI supports the reasonable implementation of this reporting requirement and opposed efforts by Farm Credit to exempt its lenders. Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Reporting Beneficial Ownership Information CBAI supports shifting the burden of collecting the BOI of community bank accountholders to the Financial Crimes Enforcement Network (FinCEN). The current requirement is flawed because it does not relieve community banks from this burden. There have been legal challenges to the reporting requirements. CBAI supports making FinCEN the sole repository of BOI and relieving community banks from this burden. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Closing the Industrial Loan Company (ILC) Regulatory Loophole CBAI has consistently supported the long-standing American policy of prohibiting the mixing of banking and commerce, which ILCs represent, because of the risks they pose to the financial system, the FDICs DIF, our economy, consumers and American taxpayers. The risk posed by ILCs, particularly large technology and ecommerce giants, is a regulatory loophole that allows their holding companies to escape from consolidated federal supervision and regulation. This loophole must be closed. Appropriate Regulation of Fintechs and Innovations in Financial Services The pace of innovation in financial services has been accelerating. Many of these new services are offered by financial technology companies - better known as fintechs. Financial innovation presents community banks with challenges and opportunities. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose unreasonable requirements on them, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. Prescriptive and Intrusive FDIC Corporate Governance Guidelines In 2023, the FDIC proposed new corporate governance and risk management guidelines. Although the guidelines only apply to covered institutions with $10 billion or more in assets, these overly prescriptive guidelines apply the same set of standards to larger community banks as they do to the nations largest banks. These guidelines would make it even more difficult to attract new directors, particularly those in rural areas. Harmful Climate Risk Regulations Community bankers high-contact and relationship-based lending model ensures that controls are in place to monitor climate risks on an ongoing basis. CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Consumer Financial Protection Bureau (CFPB) Reform and Exemptions for Community Banks CFPBs regulations must provide community banks with the flexibility to meet the needs of their customers - not a one-size-fits-all approach. They must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. In reforming the CFPB, the single director governance should be replaced by a five-member board or commission. A broader definition of firms that grant credit should be subject to the CFPB rules, and they should be robustly supervised and examined. The focus of any enhanced regulation of financial products should be on the largest banks and financial firms, the unregulated shadow financial industry, and fintechs - not community banks. De Novo Community Bank Formation, the Dual Banking System, and Charter Choice The chartering of many newly chartered (de novo) community banks is vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of continued banking industry consolidation. Hand in hand with renewed de novo bank formation is the importance of maintaining the dual banking system, where chartering and supervision are divided between the federal government and the states, and where the federal government supervision and regulation is divided between the Federal Reserve, Office of Comptroller of the Currency, and the Federal Deposit Insurance Corporation. Community banks should be able to choose the banking charter and associated prudential regulator that best fits their unique needs and business model. Sound Principles for Housing Government Sponsored Entity (GSE) Reform Reforms in government support for housing finance remain important to the future of the housing market and the U.S. economy. Unlike other private aggregators or investors, the GSEs have a mandate to serve all markets at all times, which is critical to maintaining liquidity particularly when markets are experiencing financial stress and private capital moves to the sidelines. Exiting receivership includes building capital to successfully operate within a broader housing finance framework, and bipartisan agreement on the proper role of the housing GSEs and the programs necessary to fulfill reasonable and consistent housing goals. Responsible Bank Merger Activity Some community banks have found it helpful to merge with other community banks to be able to spread the significant and escalating costs of regulatory compliance, cybersecurity, technology and innovation to remain highly competitive. Restrictive bank merger legislation or regulations should not apply to community banks. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Insure) Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts Too-Big-To-Not-Insure The 2023 failures of Silicon Valley Bank and Signature Bank revealed that policymakers have created a new category of very large banks - Too-Big-To-Not-Insure (although they will fail) because the FDIC decided to insure 100% of the uninsured deposits of these two failed banks. There must be accountability by both the banks and the regulators for their respective failures. In the future, if systemically important financial institutions (SIFIs) cause losses to the DIF then SIFIs should be responsible for reimbursing the DIF for all the losses they created. Too-Big-To-Fail The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 1799 the Threshold Modernization Act (All Sections) regarding thresholds for currency transaction reporting and Suspicious Activity Reporting (SAR) (House) H.R. 7056 the Community Bank Tailoring Act (All Sections) regarding indexing various asset-based and bank-regulatory reporting thresholds o nominal GDP for community banks (House) H.R. 6955 the Main Street Capital Access Act (All Sections) regarding regulatory fairness, transparency and right-sizing; promoting healthy, growing, and competitive banking industry; and improving access o funding and capital for small to mid-sized banks (House) H.R. 6644 the Housing for the 21st Century Act (Title VI) regarding he inclusion of FDIC modernizing insurance and reciprocal deposit rules, targeted regulatory and examination relief, lowering compliance costs, encouraging the formation of new community banks, and strengthen Minority Depository Institutions (MDIs) (House and Senate) S. 2651 or the ROAD Act which is the 21st Century ROAD to Housing Act regarding the inclusion of the provisions in H.R. 6644 (Housing for the 21st Century Act (Title VI) (House and Senate) H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Letters - Comment Letter to the FDIC regarding PayPal Holdings, Inc. application to the FDIC for deposit insurance for PayPal Bank (FDIC) Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71 (IRS) Comment Letter to the OCC, FDIC and Federal Reserve regarding Notice of Proposed Rulemaking: Regulatory Capital Rule: Revisions to the Community Bank Leverage Ratio Framework - Docket ID OCC-2025-0141, Federal Reserve Docket No. R-1876 and RIN 7100-AH08, and FDIC RIN 3064-AG17 (OCC, FDIC and Federal Reserve) Comment Letter to the Federal Reserve regarding Request for Information and Comment on Reserve Board Payment Account Prototype - Docket No. OP-1877 (aka Fed skinny payment accounts) (Federal Reserve) Comment Letter to the Federal Reserve regarding Request for Information and Comments on the Future of the Federal Reserve Banks Check Services - Docket No. OP-1874 (Federal Reserve) Comment Letter to the OCC regarding Notice of Proposed Rulemaking: Revised Guidelines - OCC Guidelines Establishing Heightened Standards for Certain Large Insured National Banks, Insured Federal Savings Associations, and Insured Federal Branches; Technical Amendments - Docket ID OCC-2025-0207 (OCC) Action Alerts - Action Alert - Urge Your Representative to Support Community Bank Regulatory Relief (House) (See H.R. 6644 Housing for the 21st Century Act above) Miscellaneous - Potential House field hearing on financial fraud (House) Approval of application for Kraken master account with the Federal Reserve (House) EGRPRA Outreach Meeting presentation on March 26, 2026, regarding de novos, particularly newly chartered community banks (OCC, FDIC, Federal Reserve)","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":54,"name":"Federal Deposit Insurance Corporation (FDIC)"},{"id":62,"name":"Federal Reserve System"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":183,"name":"Office of the Comptroller of the Currency (OCC)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"AGR","general_issue_code_display":"Agriculture","description":"CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Small Business Data Collection A Final Rule was published in March of 2023. The Final Rule was flawed because it exempted too few financial institutions and set the revenue threshold so high that it now encompasses too many businesses, in addition to raising privacy and other concerns. There have been legal challenges to the Final Rule. CBAI supports the reasonable implementation of this reporting requirement and opposed efforts by Farm Credit to exempt its lenders. Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Reporting Beneficial Ownership Information CBAI supports shifting the burden of collecting the BOI of community bank accountholders to the Financial Crimes Enforcement Network (FinCEN). The current requirement is flawed because it does not relieve community banks from this burden. There have been legal challenges to the reporting requirements. CBAI supports making FinCEN the sole repository of BOI and relieving community banks from this burden. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Harmful Climate Risk Regulations Community bankers high-contact and relationship-based lending model ensures that controls are in place to monitor climate risks on an ongoing basis. CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Sound Principles for Housing Government Sponsored Entity (GSE) Reform Reforms in government support for housing finance remain important to the future of the housing market and the U.S. economy. Unlike other private aggregators or investors, the GSEs have a mandate to serve all markets at all times, which is critical to maintaining liquidity particularly when markets are experiencing financial stress and private capital moves to the sidelines. Exiting receivership includes building capital to successfully operate within a broader housing finance framework, and bipartisan agreement on the proper role of the housing GSEs and the programs necessary to fulfill reasonable and consistent housing goals. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 6644 the Housing for the 21st Century Act (Title VI) regarding he inclusion of FDIC modernizing insurance and reciprocal deposit rules, targeted regulatory and examination relief, lowering compliance costs, encouraging the formation of new community banks, and strengthen Minority Depository Institutions (MDIs) (House) S. 2651 or the ROAD Act which is the 21st Century ROAD to Housing Act regarding the inclusion of the provisions in H.R. 6644 (Housing for the 21st Century Act (Title VI) (House and Senate) H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Letters - Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71 (IRS) Comment Letter to the Federal Reserve regarding Request for Information and Comments on the Future of the Federal Reserve Banks Check Services - Docket No. OP-1874 (Federal Reserve) Action Alerts - None Miscellaneous - Potential House field hearing on financial fraud (House)","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":62,"name":"Federal Reserve System"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"CSP","general_issue_code_display":"Consumer Issues/Safety/Products","description":"CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Legitimate Bank Service Charges and Fees are Not Hidden, Exploitive and Junk Fees and Necessary Consumer Financial Responsibility There have been misguided characterizations that community bank service charges and fees are exploitive, unfair and even unlawful. What some have disparaging called Junk fees are bank fees and service charges that are justified, disclosed, and accepted by the consumers who utilize bank products and services. CBAI does not support practices that abuse consumers, but policymakers must accept the position that it is the consumers responsibility to maintain a positive deposit account balance and make their debt payments in a timely manner. It is wrong for policymakers to excuse irresponsible consumer financial behavior and doing so may encourage unacceptable behavior. Realistic Perspective on Financial Inclusion CBAI strongly supports financial inclusion and believes every responsible and able consumer and business should have a banking relationship with their local community bank. There is indisputable proof that the banking industry excels at serving the banking needs of American households. CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the role of federal, state or governments to provide banking services. Governments can assist the private sector in financial inclusion through incentives to promote community banks offering basic accounts and small-dollar consumer loans, especially to low- and middle-income consumers, which are those most likely to be unbanked or underbanked. Protecting Consumers by Restricting the Sale of Mortgage Trigger Leads Trigger leads are generated by credit reporting agencies that contact information about consumers applying for residential mortgage loans to mortgage marketers. This practice is permitted but restricted. Our members report that many of these marketing communications fall short of the legal requirements. Trigger leads compromise consumer privacy, create a flood of unwanted (even harassing) solicitations, create confusion and result in complaints. CBAI supports legislation that would restrict credit reporting agencies from selling consumer contact information unless the applicant has opted in to receive these solicitations. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks Postal Banking CBAI believes postal banking is misguided and views any entry by the USPS into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the USPS to develop and offer banking services. Public Banking CBAI believes public banking is misguided and views any entry by federal, state or local governments into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the government to offer banking services. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Closing the Industrial Loan Company (ILC) Regulatory Loophole CBAI has consistently supported the long-standing American policy of prohibiting the mixing of banking and commerce, which ILCs represent, because of the risks they pose to the financial system, the FDICs DIF, our economy, consumers and American taxpayers. The risk posed by ILCs, particularly large technology and ecommerce giants, is a regulatory loophole that allows their holding companies to escape from consolidated federal supervision and regulation. This loophole must be closed. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Consumer Financial Protection Bureau (CFPB) Reform and Exemptions for Community Banks CFPBs regulations must provide community banks with the flexibility to meet the needs of their customers - not a one-size-fits-all approach. They must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. In reforming the CFPB, the single director governance should be replaced by a five-member board or commission. A broader definition of firms that grant credit should be subject to the CFPB rules, and they should be robustly supervised and examined. The focus of any enhanced regulation of financial products should be on the largest banks and financial firms, the unregulated shadow financial industry, and fintechs - not community banks. Sound Principles for Housing Government Sponsored Entity (GSE) Reform Reforms in government support for housing finance remain important to the future of the housing market and the U.S. economy. Unlike other private aggregators or investors, the GSEs have a mandate to serve all markets at all times, which is critical to maintaining liquidity particularly when markets are experiencing financial stress and private capital moves to the sidelines. Exiting receivership includes building capital to successfully operate within a broader housing finance framework, and bipartisan agreement on the proper role of the housing GSEs and the programs necessary to fulfill reasonable and consistent housing goals. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Letters - Comment Letter to the FDIC regarding PayPal Holdings, Inc. application to the FDIC for deposit insurance for PayPal Bank (FDIC) Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71 (IRS) Comment Letter to the Federal Reserve regarding Request for Information and Comments on the Future of the Federal Reserve Banks Check Services - Docket No. OP-1874 (Federal Reserve) Action Alerts - None Miscellaneous - Potential House field hearing on financial fraud (House) Approval of application for Kraken master account with the Federal Reserve (House)","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":54,"name":"Federal Deposit Insurance Corporation (FDIC)"},{"id":62,"name":"Federal Reserve System"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"SMB","general_issue_code_display":"Small Business","description":"CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks SBA Direct Lending Community banks and the SBA have a long, beneficial and cooperative private sector/public sector relationship and the SBA has historically not competed with banks in lending to businesses. Community banks are far superior in prudently underwriting and administering commercial lending relationships. The SBA originating and disbursing 7(a) loans will result in credit underwriting lapses which will put billions of taxpayer dollars at risk of loss. CBAI urges policymakers to prohibit the SBA from making direct 7(a) loans or otherwise expanding the institutions beyond well-regulated banks that could originate SBA loans. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Small Business Data Collection A Final Rule was published in March of 2023. The Final Rule was flawed because it exempted too few financial institutions and set the revenue threshold so high that it now encompasses too many businesses, in addition to raising privacy and other concerns. There have been legal challenges to the Final Rule. CBAI supports the reasonable implementation of this reporting requirement and opposed efforts by Farm Credit to exempt its lenders. Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Reporting Beneficial Ownership Information CBAI supports shifting the burden of collecting the BOI of community bank accountholders to the Financial Crimes Enforcement Network (FinCEN). The current requirement is flawed because it does not relieve community banks from this burden. There have been legal challenges to the reporting requirements. CBAI supports making FinCEN the sole repository of BOI and relieving community banks from this burden. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Harmful Climate Risk Regulations Community bankers high-contact and relationship-based lending model ensures that controls are in place to monitor climate risks on an ongoing basis. CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Consumer Financial Protection Bureau (CFPB) Reform and Exemptions for Community Banks CFPBs regulations must provide community banks with the flexibility to meet the needs of their customers - not a one-size-fits-all approach. They must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. In reforming the CFPB, the single director governance should be replaced by a five-member board or commission. A broader definition of firms that grant credit should be subject to the CFPB rules, and they should be robustly supervised and examined. The focus of any enhanced regulation of financial products should be on the largest banks and financial firms, the unregulated shadow financial industry, and fintechs - not community banks. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Action Alerts - None Letters - Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71 (IRS) Comment Letter to the Federal Reserve regarding Request for Information and Comments on the Future of the Federal Reserve Banks Check Services - Docket No. OP-1874 (Federal Reserve) Miscellaneous - Potential House field hearing on financial fraud (House)","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":62,"name":"Federal Reserve System"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"TAX","general_issue_code_display":"Taxation/Internal Revenue Code","description":"CBAI Federal Policy Priorities - Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Letters - Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71(IRS) Action Alerts - None Miscellaneous - None","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"ECN","general_issue_code_display":"Economics/Economic Development","description":"CBAI Federal Policy Priorities - Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 6644 the Housing for the 21st Century Act (Title VI) regarding the inclusion of FDIC modernizing insurance and reciprocal deposit rules, targeted regulatory and examination relief, lowering compliance costs, encouraging the formation of new community banks, and strengthen Minority Depository Institutions (MDIs) (House and Senate) S. 2651 or the ROAD Act which is the 21st Century ROAD to Housing Act regarding the inclusion of the provisions in H.R. 6644 (Housing for the 21st Century Act (Title VI) (House and Senate) H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Letters - Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71 (IRS) Comment Letter to the Federal Reserve regarding Request for Information and Comments on the Future of the Federal Reserve Banks Check Services - Docket No. OP-1874 (Federal Reserve) Action Alerts - Action Alert - Urge Your Representative to Support Community Bank Regulatory Relief (House) (See H.R. 6644 Housing for the 21st Century Act above) Miscellaneous - None","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":62,"name":"Federal Reserve System"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":1,"name":"SENATE"}]}],"conviction_disclosures":[],"foreign_entities":[],"affiliated_organizations":[]},{"url":"https://lda.gov/api/v1/filings/8c041376-c992-457a-94a7-eb83e0dd4f41/","filing_uuid":"8c041376-c992-457a-94a7-eb83e0dd4f41","filing_type":"Q1","filing_type_display":"1st Quarter - Report","filing_year":2026,"filing_period":"first_quarter","filing_period_display":"1st Quarter (Jan 1 - Mar 31)","filing_document_url":"https://lda.gov/filings/public/filing/8c041376-c992-457a-94a7-eb83e0dd4f41/print/","filing_document_content_type":"text/html","income":null,"expenses":"65000.00","expenses_method":"A","expenses_method_display":"A","posted_by_name":"David G Schroeder","dt_posted":"2026-04-10T15:38:54-04:00","termination_date":null,"registrant_country":"United States of America","registrant_ppb_country":null,"registrant_address_1":"901 Community Drive","registrant_address_2":null,"registrant_different_address":false,"registrant_city":"Springfield","registrant_state":"IL","registrant_zip":"62703","registrant":{"id":400531588,"url":"https://lda.gov/api/v1/registrants/400531588/","house_registrant_id":null,"name":"COMMUNITY BANKERS ASSOCIATION OF ILLINOIS","description":"Trade association representing Illinois' community banks and thrifts","address_1":"901 Community Drive","address_2":null,"address_3":null,"address_4":null,"city":"Springfield","state":"IL","state_display":"Illinois","zip":"62703","country":"US","country_display":"United States of America","ppb_country":"US","ppb_country_display":"United States of America","contact_name":"DAVID G. SCHROEDER","contact_telephone":"+1 847-909-8341","dt_updated":"2026-07-28T17:21:17.493355-04:00"},"client":{"id":192301,"url":"https://lda.gov/api/v1/clients/192301/","client_id":12,"name":"COMMUNITY BANKERS ASSOCIATION OF ILLINOIS","general_description":null,"client_government_entity":false,"client_self_select":true,"state":"IL","state_display":"Illinois","country":"US","country_display":"United States of America","ppb_state":"IL","ppb_state_display":"Illinois","ppb_country":"US","ppb_country_display":"United States of America","effective_date":"2010-01-01"},"lobbying_activities":[{"general_issue_code":"BAN","general_issue_code_display":"Banking","description":"CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. Legitimate Bank Service Charges and Fees are Not Hidden, Exploitive and Junk Fees and Necessary Consumer Financial Responsibility There have been misguided characterizations that community bank service charges and fees are exploitive, unfair and even unlawful. What some have disparaging called Junk fees are bank fees and service charges that are justified, disclosed, and accepted by the consumers who utilize bank products and services. CBAI does not support practices that abuse consumers, but policymakers must accept the position that it is the consumers responsibility to maintain a positive deposit account balance and make their debt payments in a timely manner. It is wrong for policymakers to excuse irresponsible consumer financial behavior and doing so may encourage unacceptable behavior. Realistic Perspective on Financial Inclusion CBAI strongly supports financial inclusion and believes every responsible and able consumer and business should have a banking relationship with their local community bank. There is indisputable proof that the banking industry excels at serving the banking needs of American households. CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the role of federal, state or governments to provide banking services. Governments can assist the private sector in financial inclusion through incentives to promote community banks offering basic accounts and small-dollar consumer loans, especially to low- and middle-income consumers, which are those most likely to be unbanked or underbanked. Protecting Consumers by Restricting the Sale of Mortgage Trigger Leads Trigger leads are generated by credit reporting agencies that contact information about consumers applying for residential mortgage loans to mortgage marketers. This practice is permitted but restricted. Our members report that many of these marketing communications fall short of the legal requirements. Trigger leads compromise consumer privacy, create a flood of unwanted (even harassing) solicitations, create confusion and result in complaints. CBAI supports legislation that would restrict credit reporting agencies from selling consumer contact information unless the applicant has opted in to receive these solicitations. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks SBA Direct Lending Community banks and the SBA have a long, beneficial and cooperative private sector/public sector relationship and the SBA has historically not competed with banks in lending to businesses. Community banks are far superior in prudently underwriting and administering commercial lending relationships. The SBA originating and disbursing 7(a) loans will result in credit underwriting lapses which will put billions of taxpayer dollars at risk of loss. CBAI urges policymakers to prohibit the SBA from making direct 7(a) loans or otherwise expanding the institutions beyond well-regulated banks that could originate SBA loans. Postal Banking CBAI believes postal banking is misguided and views any entry by the USPS into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the USPS to develop and offer banking services. Public Banking CBAI believes public banking is misguided and views any entry by federal, state or local governments into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the government to offer banking services. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Small Business Data Collection A Final Rule was published in March of 2023. The Final Rule was flawed because it exempted too few financial institutions and set the revenue threshold so high that it now encompasses too many businesses, in addition to raising privacy and other concerns. There have been legal challenges to the Final Rule. CBAI supports the reasonable implementation of this reporting requirement and opposed efforts by Farm Credit to exempt its lenders. Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Reporting Beneficial Ownership Information CBAI supports shifting the burden of collecting the BOI of community bank accountholders to the Financial Crimes Enforcement Network (FinCEN). The current requirement is flawed because it does not relieve community banks from this burden. There have been legal challenges to the reporting requirements. CBAI supports making FinCEN the sole repository of BOI and relieving community banks from this burden. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Closing the Industrial Loan Company (ILC) Regulatory Loophole CBAI has consistently supported the long-standing American policy of prohibiting the mixing of banking and commerce, which ILCs represent, because of the risks they pose to the financial system, the FDICs DIF, our economy, consumers and American taxpayers. The risk posed by ILCs, particularly large technology and ecommerce giants, is a regulatory loophole that allows their holding companies to escape from consolidated federal supervision and regulation. This loophole must be closed. Appropriate Regulation of Fintechs and Innovations in Financial Services The pace of innovation in financial services has been accelerating. Many of these new services are offered by financial technology companies - better known as fintechs. Financial innovation presents community banks with challenges and opportunities. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose unreasonable requirements on them, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. Prescriptive and Intrusive FDIC Corporate Governance Guidelines In 2023, the FDIC proposed new corporate governance and risk management guidelines. Although the guidelines only apply to covered institutions with $10 billion or more in assets, these overly prescriptive guidelines apply the same set of standards to larger community banks as they do to the nations largest banks. These guidelines would make it even more difficult to attract new directors, particularly those in rural areas. Harmful Climate Risk Regulations Community bankers high-contact and relationship-based lending model ensures that controls are in place to monitor climate risks on an ongoing basis. CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Consumer Financial Protection Bureau (CFPB) Reform and Exemptions for Community Banks CFPBs regulations must provide community banks with the flexibility to meet the needs of their customers - not a one-size-fits-all approach. They must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. In reforming the CFPB, the single director governance should be replaced by a five-member board or commission. A broader definition of firms that grant credit should be subject to the CFPB rules, and they should be robustly supervised and examined. The focus of any enhanced regulation of financial products should be on the largest banks and financial firms, the unregulated shadow financial industry, and fintechs - not community banks. De Novo Community Bank Formation, the Dual Banking System, and Charter Choice The chartering of many newly chartered (de novo) community banks is vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of continued banking industry consolidation. Hand in hand with renewed de novo bank formation is the importance of maintaining the dual banking system, where chartering and supervision are divided between the federal government and the states, and where the federal government supervision and regulation is divided between the Federal Reserve, Office of Comptroller of the Currency, and the Federal Deposit Insurance Corporation. Community banks should be able to choose the banking charter and associated prudential regulator that best fits their unique needs and business model. Sound Principles for Housing Government Sponsored Entity (GSE) Reform Reforms in government support for housing finance remain important to the future of the housing market and the U.S. economy. Unlike other private aggregators or investors, the GSEs have a mandate to serve all markets at all times, which is critical to maintaining liquidity particularly when markets are experiencing financial stress and private capital moves to the sidelines. Exiting receivership includes building capital to successfully operate within a broader housing finance framework, and bipartisan agreement on the proper role of the housing GSEs and the programs necessary to fulfill reasonable and consistent housing goals. Responsible Bank Merger Activity Some community banks have found it helpful to merge with other community banks to be able to spread the significant and escalating costs of regulatory compliance, cybersecurity, technology and innovation to remain highly competitive. Restrictive bank merger legislation or regulations should not apply to community banks. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Insure) Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts Too-Big-To-Not-Insure The 2023 failures of Silicon Valley Bank and Signature Bank revealed that policymakers have created a new category of very large banks - Too-Big-To-Not-Insure (although they will fail) because the FDIC decided to insure 100% of the uninsured deposits of these two failed banks. There must be accountability by both the banks and the regulators for their respective failures. In the future, if systemically important financial institutions (SIFIs) cause losses to the DIF then SIFIs should be responsible for reimbursing the DIF for all the losses they created. Too-Big-To-Fail The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 1799 the Threshold Modernization Act (All Sections) regarding thresholds for currency transaction reporting and Suspicious Activity Reporting (SAR) (House) H.R. 7056 the Community Bank Tailoring Act (All Sections) regarding indexing various asset-based and bank-regulatory reporting thresholds o nominal GDP for community banks (House) H.R. 6955 the Main Street Capital Access Act (All Sections) regarding regulatory fairness, transparency and right-sizing; promoting healthy, growing, and competitive banking industry; and improving access o funding and capital for small to mid-sized banks (House) H.R. 6644 the Housing for the 21st Century Act (Title VI) regarding he inclusion of FDIC modernizing insurance and reciprocal deposit rules, targeted regulatory and examination relief, lowering compliance costs, encouraging the formation of new community banks, and strengthen Minority Depository Institutions (MDIs) (House and Senate) S. 2651 or the ROAD Act which is the 21st Century ROAD to Housing Act regarding the inclusion of the provisions in H.R. 6644 (Housing for the 21st Century Act (Title VI) (House and Senate) H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Letters - Comment Letter to the FDIC regarding PayPal Holdings, Inc. application to the FDIC for deposit insurance for PayPal Bank (FDIC) Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71 (IRS) Comment Letter to the OCC, FDIC and Federal Reserve regarding Notice of Proposed Rulemaking: Regulatory Capital Rule: Revisions to the Community Bank Leverage Ratio Framework - Docket ID OCC-2025-0141, Federal Reserve Docket No. R-1876 and RIN 7100-AH08, and FDIC RIN 3064-AG17 (OCC, FDIC and Federal Reserve) Comment Letter to the Federal Reserve regarding Request for Information and Comment on Reserve Board Payment Account Prototype - Docket No. OP-1877 (aka Fed skinny payment accounts) (Federal Reserve) Comment Letter to the Federal Reserve regarding Request for Information and Comments on the Future of the Federal Reserve Banks Check Services - Docket No. OP-1874 (Federal Reserve) Comment Letter to the OCC regarding Notice of Proposed Rulemaking: Revised Guidelines - OCC Guidelines Establishing Heightened Standards for Certain Large Insured National Banks, Insured Federal Savings Associations, and Insured Federal Branches; Technical Amendments - Docket ID OCC-2025-0207 (OCC) Action Alerts - Action Alert - Urge Your Representative to Support Community Bank Regulatory Relief (House) (See H.R. 6644 Housing for the 21st Century Act above) Miscellaneous - Potential House field hearing on financial fraud (House) Approval of application for Kraken master account with the Federal Reserve (House) EGRPRA Outreach Meeting presentation on March 26, 2026, regarding de novos, particularly newly chartered community banks (OCC, FDIC, Federal Reserve)","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":54,"name":"Federal Deposit Insurance Corporation (FDIC)"},{"id":62,"name":"Federal Reserve System"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":183,"name":"Office of the Comptroller of the Currency (OCC)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"FIN","general_issue_code_display":"Financial Institutions/Investments/Securities","description":"CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. Legitimate Bank Service Charges and Fees are Not Hidden, Exploitive and Junk Fees and Necessary Consumer Financial Responsibility There have been misguided characterizations that community bank service charges and fees are exploitive, unfair and even unlawful. What some have disparaging called Junk fees are bank fees and service charges that are justified, disclosed, and accepted by the consumers who utilize bank products and services. CBAI does not support practices that abuse consumers, but policymakers must accept the position that it is the consumers responsibility to maintain a positive deposit account balance and make their debt payments in a timely manner. It is wrong for policymakers to excuse irresponsible consumer financial behavior and doing so may encourage unacceptable behavior. Realistic Perspective on Financial Inclusion CBAI strongly supports financial inclusion and believes every responsible and able consumer and business should have a banking relationship with their local community bank. There is indisputable proof that the banking industry excels at serving the banking needs of American households. CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the role of federal, state or governments to provide banking services. Governments can assist the private sector in financial inclusion through incentives to promote community banks offering basic accounts and small-dollar consumer loans, especially to low- and middle-income consumers, which are those most likely to be unbanked or underbanked. Protecting Consumers by Restricting the Sale of Mortgage Trigger Leads Trigger leads are generated by credit reporting agencies that contact information about consumers applying for residential mortgage loans to mortgage marketers. This practice is permitted but restricted. Our members report that many of these marketing communications fall short of the legal requirements. Trigger leads compromise consumer privacy, create a flood of unwanted (even harassing) solicitations, create confusion and result in complaints. CBAI supports legislation that would restrict credit reporting agencies from selling consumer contact information unless the applicant has opted in to receive these solicitations. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks SBA Direct Lending Community banks and the SBA have a long, beneficial and cooperative private sector/public sector relationship and the SBA has historically not competed with banks in lending to businesses. Community banks are far superior in prudently underwriting and administering commercial lending relationships. The SBA originating and disbursing 7(a) loans will result in credit underwriting lapses which will put billions of taxpayer dollars at risk of loss. CBAI urges policymakers to prohibit the SBA from making direct 7(a) loans or otherwise expanding the institutions beyond well-regulated banks that could originate SBA loans. Postal Banking CBAI believes postal banking is misguided and views any entry by the USPS into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the USPS to develop and offer banking services. Public Banking CBAI believes public banking is misguided and views any entry by federal, state or local governments into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the government to offer banking services. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Small Business Data Collection A Final Rule was published in March of 2023. The Final Rule was flawed because it exempted too few financial institutions and set the revenue threshold so high that it now encompasses too many businesses, in addition to raising privacy and other concerns. There have been legal challenges to the Final Rule. CBAI supports the reasonable implementation of this reporting requirement and opposed efforts by Farm Credit to exempt its lenders. Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Reporting Beneficial Ownership Information CBAI supports shifting the burden of collecting the BOI of community bank accountholders to the Financial Crimes Enforcement Network (FinCEN). The current requirement is flawed because it does not relieve community banks from this burden. There have been legal challenges to the reporting requirements. CBAI supports making FinCEN the sole repository of BOI and relieving community banks from this burden. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Closing the Industrial Loan Company (ILC) Regulatory Loophole CBAI has consistently supported the long-standing American policy of prohibiting the mixing of banking and commerce, which ILCs represent, because of the risks they pose to the financial system, the FDICs DIF, our economy, consumers and American taxpayers. The risk posed by ILCs, particularly large technology and ecommerce giants, is a regulatory loophole that allows their holding companies to escape from consolidated federal supervision and regulation. This loophole must be closed. Appropriate Regulation of Fintechs and Innovations in Financial Services The pace of innovation in financial services has been accelerating. Many of these new services are offered by financial technology companies - better known as fintechs. Financial innovation presents community banks with challenges and opportunities. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose unreasonable requirements on them, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. Prescriptive and Intrusive FDIC Corporate Governance Guidelines In 2023, the FDIC proposed new corporate governance and risk management guidelines. Although the guidelines only apply to covered institutions with $10 billion or more in assets, these overly prescriptive guidelines apply the same set of standards to larger community banks as they do to the nations largest banks. These guidelines would make it even more difficult to attract new directors, particularly those in rural areas. Harmful Climate Risk Regulations Community bankers high-contact and relationship-based lending model ensures that controls are in place to monitor climate risks on an ongoing basis. CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Consumer Financial Protection Bureau (CFPB) Reform and Exemptions for Community Banks CFPBs regulations must provide community banks with the flexibility to meet the needs of their customers - not a one-size-fits-all approach. They must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. In reforming the CFPB, the single director governance should be replaced by a five-member board or commission. A broader definition of firms that grant credit should be subject to the CFPB rules, and they should be robustly supervised and examined. The focus of any enhanced regulation of financial products should be on the largest banks and financial firms, the unregulated shadow financial industry, and fintechs - not community banks. De Novo Community Bank Formation, the Dual Banking System, and Charter Choice The chartering of many newly chartered (de novo) community banks is vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of continued banking industry consolidation. Hand in hand with renewed de novo bank formation is the importance of maintaining the dual banking system, where chartering and supervision are divided between the federal government and the states, and where the federal government supervision and regulation is divided between the Federal Reserve, Office of Comptroller of the Currency, and the Federal Deposit Insurance Corporation. Community banks should be able to choose the banking charter and associated prudential regulator that best fits their unique needs and business model. Sound Principles for Housing Government Sponsored Entity (GSE) Reform Reforms in government support for housing finance remain important to the future of the housing market and the U.S. economy. Unlike other private aggregators or investors, the GSEs have a mandate to serve all markets at all times, which is critical to maintaining liquidity particularly when markets are experiencing financial stress and private capital moves to the sidelines. Exiting receivership includes building capital to successfully operate within a broader housing finance framework, and bipartisan agreement on the proper role of the housing GSEs and the programs necessary to fulfill reasonable and consistent housing goals. Responsible Bank Merger Activity Some community banks have found it helpful to merge with other community banks to be able to spread the significant and escalating costs of regulatory compliance, cybersecurity, technology and innovation to remain highly competitive. Restrictive bank merger legislation or regulations should not apply to community banks. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Insure) Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts Too-Big-To-Not-Insure The 2023 failures of Silicon Valley Bank and Signature Bank revealed that policymakers have created a new category of very large banks - Too-Big-To-Not-Insure (although they will fail) because the FDIC decided to insure 100% of the uninsured deposits of these two failed banks. There must be accountability by both the banks and the regulators for their respective failures. In the future, if systemically important financial institutions (SIFIs) cause losses to the DIF then SIFIs should be responsible for reimbursing the DIF for all the losses they created. Too-Big-To-Fail The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 1799 the Threshold Modernization Act (All Sections) regarding thresholds for currency transaction reporting and Suspicious Activity Reporting (SAR) (House) H.R. 7056 the Community Bank Tailoring Act (All Sections) regarding indexing various asset-based and bank-regulatory reporting thresholds o nominal GDP for community banks (House) H.R. 6955 the Main Street Capital Access Act (All Sections) regarding regulatory fairness, transparency and right-sizing; promoting healthy, growing, and competitive banking industry; and improving access o funding and capital for small to mid-sized banks (House) H.R. 6644 the Housing for the 21st Century Act (Title VI) regarding he inclusion of FDIC modernizing insurance and reciprocal deposit rules, targeted regulatory and examination relief, lowering compliance costs, encouraging the formation of new community banks, and strengthen Minority Depository Institutions (MDIs) (House and Senate) S. 2651 or the ROAD Act which is the 21st Century ROAD to Housing Act regarding the inclusion of the provisions in H.R. 6644 (Housing for the 21st Century Act (Title VI) (House and Senate) H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Letters - Comment Letter to the FDIC regarding PayPal Holdings, Inc. application to the FDIC for deposit insurance for PayPal Bank (FDIC) Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71 (IRS) Comment Letter to the OCC, FDIC and Federal Reserve regarding Notice of Proposed Rulemaking: Regulatory Capital Rule: Revisions to the Community Bank Leverage Ratio Framework - Docket ID OCC-2025-0141, Federal Reserve Docket No. R-1876 and RIN 7100-AH08, and FDIC RIN 3064-AG17 (OCC, FDIC and Federal Reserve) Comment Letter to the Federal Reserve regarding Request for Information and Comment on Reserve Board Payment Account Prototype - Docket No. OP-1877 (aka Fed skinny payment accounts) (Federal Reserve) Comment Letter to the Federal Reserve regarding Request for Information and Comments on the Future of the Federal Reserve Banks Check Services - Docket No. OP-1874 (Federal Reserve) Comment Letter to the OCC regarding Notice of Proposed Rulemaking: Revised Guidelines - OCC Guidelines Establishing Heightened Standards for Certain Large Insured National Banks, Insured Federal Savings Associations, and Insured Federal Branches; Technical Amendments - Docket ID OCC-2025-0207 (OCC) Action Alerts - Action Alert - Urge Your Representative to Support Community Bank Regulatory Relief (House) (See H.R. 6644 Housing for the 21st Century Act above) Miscellaneous - Potential House field hearing on financial fraud (House) Approval of application for Kraken master account with the Federal Reserve (House) EGRPRA Outreach Meeting presentation on March 26, 2026, regarding de novos, particularly newly chartered community banks (OCC, FDIC, Federal Reserve)","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":54,"name":"Federal Deposit Insurance Corporation (FDIC)"},{"id":62,"name":"Federal Reserve System"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":183,"name":"Office of the Comptroller of the Currency (OCC)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"AGR","general_issue_code_display":"Agriculture","description":"CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Small Business Data Collection A Final Rule was published in March of 2023. The Final Rule was flawed because it exempted too few financial institutions and set the revenue threshold so high that it now encompasses too many businesses, in addition to raising privacy and other concerns. There have been legal challenges to the Final Rule. CBAI supports the reasonable implementation of this reporting requirement and opposed efforts by Farm Credit to exempt its lenders. Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Reporting Beneficial Ownership Information CBAI supports shifting the burden of collecting the BOI of community bank accountholders to the Financial Crimes Enforcement Network (FinCEN). The current requirement is flawed because it does not relieve community banks from this burden. There have been legal challenges to the reporting requirements. CBAI supports making FinCEN the sole repository of BOI and relieving community banks from this burden. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Harmful Climate Risk Regulations Community bankers high-contact and relationship-based lending model ensures that controls are in place to monitor climate risks on an ongoing basis. CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Sound Principles for Housing Government Sponsored Entity (GSE) Reform Reforms in government support for housing finance remain important to the future of the housing market and the U.S. economy. Unlike other private aggregators or investors, the GSEs have a mandate to serve all markets at all times, which is critical to maintaining liquidity particularly when markets are experiencing financial stress and private capital moves to the sidelines. Exiting receivership includes building capital to successfully operate within a broader housing finance framework, and bipartisan agreement on the proper role of the housing GSEs and the programs necessary to fulfill reasonable and consistent housing goals. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 6644 the Housing for the 21st Century Act (Title VI) regarding he inclusion of FDIC modernizing insurance and reciprocal deposit rules, targeted regulatory and examination relief, lowering compliance costs, encouraging the formation of new community banks, and strengthen Minority Depository Institutions (MDIs) (House) S. 2651 or the ROAD Act which is the 21st Century ROAD to Housing Act regarding the inclusion of the provisions in H.R. 6644 (Housing for the 21st Century Act (Title VI) (House and Senate) H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Letters - Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71 (IRS) Comment Letter to the Federal Reserve regarding Request for Information and Comments on the Future of the Federal Reserve Banks Check Services - Docket No. OP-1874 (Federal Reserve) Action Alerts - None Miscellaneous - Potential House field hearing on financial fraud (House)","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":62,"name":"Federal Reserve System"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"CSP","general_issue_code_display":"Consumer Issues/Safety/Products","description":"CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Legitimate Bank Service Charges and Fees are Not Hidden, Exploitive and Junk Fees and Necessary Consumer Financial Responsibility There have been misguided characterizations that community bank service charges and fees are exploitive, unfair and even unlawful. What some have disparaging called Junk fees are bank fees and service charges that are justified, disclosed, and accepted by the consumers who utilize bank products and services. CBAI does not support practices that abuse consumers, but policymakers must accept the position that it is the consumers responsibility to maintain a positive deposit account balance and make their debt payments in a timely manner. It is wrong for policymakers to excuse irresponsible consumer financial behavior and doing so may encourage unacceptable behavior. Realistic Perspective on Financial Inclusion CBAI strongly supports financial inclusion and believes every responsible and able consumer and business should have a banking relationship with their local community bank. There is indisputable proof that the banking industry excels at serving the banking needs of American households. CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the role of federal, state or governments to provide banking services. Governments can assist the private sector in financial inclusion through incentives to promote community banks offering basic accounts and small-dollar consumer loans, especially to low- and middle-income consumers, which are those most likely to be unbanked or underbanked. Protecting Consumers by Restricting the Sale of Mortgage Trigger Leads Trigger leads are generated by credit reporting agencies that contact information about consumers applying for residential mortgage loans to mortgage marketers. This practice is permitted but restricted. Our members report that many of these marketing communications fall short of the legal requirements. Trigger leads compromise consumer privacy, create a flood of unwanted (even harassing) solicitations, create confusion and result in complaints. CBAI supports legislation that would restrict credit reporting agencies from selling consumer contact information unless the applicant has opted in to receive these solicitations. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks Postal Banking CBAI believes postal banking is misguided and views any entry by the USPS into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the USPS to develop and offer banking services. Public Banking CBAI believes public banking is misguided and views any entry by federal, state or local governments into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the government to offer banking services. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Closing the Industrial Loan Company (ILC) Regulatory Loophole CBAI has consistently supported the long-standing American policy of prohibiting the mixing of banking and commerce, which ILCs represent, because of the risks they pose to the financial system, the FDICs DIF, our economy, consumers and American taxpayers. The risk posed by ILCs, particularly large technology and ecommerce giants, is a regulatory loophole that allows their holding companies to escape from consolidated federal supervision and regulation. This loophole must be closed. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Consumer Financial Protection Bureau (CFPB) Reform and Exemptions for Community Banks CFPBs regulations must provide community banks with the flexibility to meet the needs of their customers - not a one-size-fits-all approach. They must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. In reforming the CFPB, the single director governance should be replaced by a five-member board or commission. A broader definition of firms that grant credit should be subject to the CFPB rules, and they should be robustly supervised and examined. The focus of any enhanced regulation of financial products should be on the largest banks and financial firms, the unregulated shadow financial industry, and fintechs - not community banks. Sound Principles for Housing Government Sponsored Entity (GSE) Reform Reforms in government support for housing finance remain important to the future of the housing market and the U.S. economy. Unlike other private aggregators or investors, the GSEs have a mandate to serve all markets at all times, which is critical to maintaining liquidity particularly when markets are experiencing financial stress and private capital moves to the sidelines. Exiting receivership includes building capital to successfully operate within a broader housing finance framework, and bipartisan agreement on the proper role of the housing GSEs and the programs necessary to fulfill reasonable and consistent housing goals. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Letters - Comment Letter to the FDIC regarding PayPal Holdings, Inc. application to the FDIC for deposit insurance for PayPal Bank (FDIC) Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71 (IRS) Comment Letter to the Federal Reserve regarding Request for Information and Comments on the Future of the Federal Reserve Banks Check Services - Docket No. OP-1874 (Federal Reserve) Action Alerts - None Miscellaneous - Potential House field hearing on financial fraud (House) Approval of application for Kraken master account with the Federal Reserve (House)","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":54,"name":"Federal Deposit Insurance Corporation (FDIC)"},{"id":62,"name":"Federal Reserve System"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"SMB","general_issue_code_display":"Small Business","description":"CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks SBA Direct Lending Community banks and the SBA have a long, beneficial and cooperative private sector/public sector relationship and the SBA has historically not competed with banks in lending to businesses. Community banks are far superior in prudently underwriting and administering commercial lending relationships. The SBA originating and disbursing 7(a) loans will result in credit underwriting lapses which will put billions of taxpayer dollars at risk of loss. CBAI urges policymakers to prohibit the SBA from making direct 7(a) loans or otherwise expanding the institutions beyond well-regulated banks that could originate SBA loans. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Small Business Data Collection A Final Rule was published in March of 2023. The Final Rule was flawed because it exempted too few financial institutions and set the revenue threshold so high that it now encompasses too many businesses, in addition to raising privacy and other concerns. There have been legal challenges to the Final Rule. CBAI supports the reasonable implementation of this reporting requirement and opposed efforts by Farm Credit to exempt its lenders. Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Reporting Beneficial Ownership Information CBAI supports shifting the burden of collecting the BOI of community bank accountholders to the Financial Crimes Enforcement Network (FinCEN). The current requirement is flawed because it does not relieve community banks from this burden. There have been legal challenges to the reporting requirements. CBAI supports making FinCEN the sole repository of BOI and relieving community banks from this burden. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Harmful Climate Risk Regulations Community bankers high-contact and relationship-based lending model ensures that controls are in place to monitor climate risks on an ongoing basis. CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Consumer Financial Protection Bureau (CFPB) Reform and Exemptions for Community Banks CFPBs regulations must provide community banks with the flexibility to meet the needs of their customers - not a one-size-fits-all approach. They must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. In reforming the CFPB, the single director governance should be replaced by a five-member board or commission. A broader definition of firms that grant credit should be subject to the CFPB rules, and they should be robustly supervised and examined. The focus of any enhanced regulation of financial products should be on the largest banks and financial firms, the unregulated shadow financial industry, and fintechs - not community banks. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Action Alerts - None Letters - Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71 (IRS) Comment Letter to the Federal Reserve regarding Request for Information and Comments on the Future of the Federal Reserve Banks Check Services - Docket No. OP-1874 (Federal Reserve) Miscellaneous - Potential House field hearing on financial fraud (House)","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":62,"name":"Federal Reserve System"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"TAX","general_issue_code_display":"Taxation/Internal Revenue Code","description":"CBAI Federal Policy Priorities - Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Letters - Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71(IRS) Action Alerts - None Miscellaneous - None","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"ECN","general_issue_code_display":"Economics/Economic Development","description":"CBAI Federal Policy Priorities - Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 6644 the Housing for the 21st Century Act (Title VI) regarding the inclusion of FDIC modernizing insurance and reciprocal deposit rules, targeted regulatory and examination relief, lowering compliance costs, encouraging the formation of new community banks, and strengthen Minority Depository Institutions (MDIs) (House and Senate) S. 2651 or the ROAD Act which is the 21st Century ROAD to Housing Act regarding the inclusion of the provisions in H.R. 6644 (Housing for the 21st Century Act (Title VI) (House and Senate) H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Letters - Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71 (IRS) Comment Letter to the Federal Reserve regarding Request for Information and Comments on the Future of the Federal Reserve Banks Check Services - Docket No. OP-1874 (Federal Reserve) Action Alerts - Action Alert - Urge Your Representative to Support Community Bank Regulatory Relief (House) (See H.R. 6644 Housing for the 21st Century Act above) Miscellaneous - None","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":62,"name":"Federal Reserve System"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":1,"name":"SENATE"}]}],"conviction_disclosures":[],"foreign_entities":[],"affiliated_organizations":[]},{"url":"https://lda.gov/api/v1/filings/8c041376-c992-457a-94a7-eb83e0dd4f41/","filing_uuid":"8c041376-c992-457a-94a7-eb83e0dd4f41","filing_type":"Q1","filing_type_display":"1st Quarter - Report","filing_year":2026,"filing_period":"first_quarter","filing_period_display":"1st Quarter (Jan 1 - Mar 31)","filing_document_url":"https://lda.gov/filings/public/filing/8c041376-c992-457a-94a7-eb83e0dd4f41/print/","filing_document_content_type":"text/html","income":null,"expenses":"65000.00","expenses_method":"A","expenses_method_display":"A","posted_by_name":"David G Schroeder","dt_posted":"2026-04-10T15:38:54-04:00","termination_date":null,"registrant_country":"United States of America","registrant_ppb_country":null,"registrant_address_1":"901 Community Drive","registrant_address_2":null,"registrant_different_address":false,"registrant_city":"Springfield","registrant_state":"IL","registrant_zip":"62703","registrant":{"id":400531588,"url":"https://lda.gov/api/v1/registrants/400531588/","house_registrant_id":null,"name":"COMMUNITY BANKERS ASSOCIATION OF ILLINOIS","description":"Trade association representing Illinois' community banks and thrifts","address_1":"901 Community Drive","address_2":null,"address_3":null,"address_4":null,"city":"Springfield","state":"IL","state_display":"Illinois","zip":"62703","country":"US","country_display":"United States of America","ppb_country":"US","ppb_country_display":"United States of America","contact_name":"DAVID G. SCHROEDER","contact_telephone":"+1 847-909-8341","dt_updated":"2026-07-28T17:21:17.493355-04:00"},"client":{"id":192301,"url":"https://lda.gov/api/v1/clients/192301/","client_id":12,"name":"COMMUNITY BANKERS ASSOCIATION OF ILLINOIS","general_description":null,"client_government_entity":false,"client_self_select":true,"state":"IL","state_display":"Illinois","country":"US","country_display":"United States of America","ppb_state":"IL","ppb_state_display":"Illinois","ppb_country":"US","ppb_country_display":"United States of America","effective_date":"2010-01-01"},"lobbying_activities":[{"general_issue_code":"BAN","general_issue_code_display":"Banking","description":"CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. Legitimate Bank Service Charges and Fees are Not Hidden, Exploitive and Junk Fees and Necessary Consumer Financial Responsibility There have been misguided characterizations that community bank service charges and fees are exploitive, unfair and even unlawful. What some have disparaging called Junk fees are bank fees and service charges that are justified, disclosed, and accepted by the consumers who utilize bank products and services. CBAI does not support practices that abuse consumers, but policymakers must accept the position that it is the consumers responsibility to maintain a positive deposit account balance and make their debt payments in a timely manner. It is wrong for policymakers to excuse irresponsible consumer financial behavior and doing so may encourage unacceptable behavior. Realistic Perspective on Financial Inclusion CBAI strongly supports financial inclusion and believes every responsible and able consumer and business should have a banking relationship with their local community bank. There is indisputable proof that the banking industry excels at serving the banking needs of American households. CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the role of federal, state or governments to provide banking services. Governments can assist the private sector in financial inclusion through incentives to promote community banks offering basic accounts and small-dollar consumer loans, especially to low- and middle-income consumers, which are those most likely to be unbanked or underbanked. Protecting Consumers by Restricting the Sale of Mortgage Trigger Leads Trigger leads are generated by credit reporting agencies that contact information about consumers applying for residential mortgage loans to mortgage marketers. This practice is permitted but restricted. Our members report that many of these marketing communications fall short of the legal requirements. Trigger leads compromise consumer privacy, create a flood of unwanted (even harassing) solicitations, create confusion and result in complaints. CBAI supports legislation that would restrict credit reporting agencies from selling consumer contact information unless the applicant has opted in to receive these solicitations. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks SBA Direct Lending Community banks and the SBA have a long, beneficial and cooperative private sector/public sector relationship and the SBA has historically not competed with banks in lending to businesses. Community banks are far superior in prudently underwriting and administering commercial lending relationships. The SBA originating and disbursing 7(a) loans will result in credit underwriting lapses which will put billions of taxpayer dollars at risk of loss. CBAI urges policymakers to prohibit the SBA from making direct 7(a) loans or otherwise expanding the institutions beyond well-regulated banks that could originate SBA loans. Postal Banking CBAI believes postal banking is misguided and views any entry by the USPS into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the USPS to develop and offer banking services. Public Banking CBAI believes public banking is misguided and views any entry by federal, state or local governments into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the government to offer banking services. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Small Business Data Collection A Final Rule was published in March of 2023. The Final Rule was flawed because it exempted too few financial institutions and set the revenue threshold so high that it now encompasses too many businesses, in addition to raising privacy and other concerns. There have been legal challenges to the Final Rule. CBAI supports the reasonable implementation of this reporting requirement and opposed efforts by Farm Credit to exempt its lenders. Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Reporting Beneficial Ownership Information CBAI supports shifting the burden of collecting the BOI of community bank accountholders to the Financial Crimes Enforcement Network (FinCEN). The current requirement is flawed because it does not relieve community banks from this burden. There have been legal challenges to the reporting requirements. CBAI supports making FinCEN the sole repository of BOI and relieving community banks from this burden. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Closing the Industrial Loan Company (ILC) Regulatory Loophole CBAI has consistently supported the long-standing American policy of prohibiting the mixing of banking and commerce, which ILCs represent, because of the risks they pose to the financial system, the FDICs DIF, our economy, consumers and American taxpayers. The risk posed by ILCs, particularly large technology and ecommerce giants, is a regulatory loophole that allows their holding companies to escape from consolidated federal supervision and regulation. This loophole must be closed. Appropriate Regulation of Fintechs and Innovations in Financial Services The pace of innovation in financial services has been accelerating. Many of these new services are offered by financial technology companies - better known as fintechs. Financial innovation presents community banks with challenges and opportunities. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose unreasonable requirements on them, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. Prescriptive and Intrusive FDIC Corporate Governance Guidelines In 2023, the FDIC proposed new corporate governance and risk management guidelines. Although the guidelines only apply to covered institutions with $10 billion or more in assets, these overly prescriptive guidelines apply the same set of standards to larger community banks as they do to the nations largest banks. These guidelines would make it even more difficult to attract new directors, particularly those in rural areas. Harmful Climate Risk Regulations Community bankers high-contact and relationship-based lending model ensures that controls are in place to monitor climate risks on an ongoing basis. CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Consumer Financial Protection Bureau (CFPB) Reform and Exemptions for Community Banks CFPBs regulations must provide community banks with the flexibility to meet the needs of their customers - not a one-size-fits-all approach. They must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. In reforming the CFPB, the single director governance should be replaced by a five-member board or commission. A broader definition of firms that grant credit should be subject to the CFPB rules, and they should be robustly supervised and examined. The focus of any enhanced regulation of financial products should be on the largest banks and financial firms, the unregulated shadow financial industry, and fintechs - not community banks. De Novo Community Bank Formation, the Dual Banking System, and Charter Choice The chartering of many newly chartered (de novo) community banks is vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of continued banking industry consolidation. Hand in hand with renewed de novo bank formation is the importance of maintaining the dual banking system, where chartering and supervision are divided between the federal government and the states, and where the federal government supervision and regulation is divided between the Federal Reserve, Office of Comptroller of the Currency, and the Federal Deposit Insurance Corporation. Community banks should be able to choose the banking charter and associated prudential regulator that best fits their unique needs and business model. Sound Principles for Housing Government Sponsored Entity (GSE) Reform Reforms in government support for housing finance remain important to the future of the housing market and the U.S. economy. Unlike other private aggregators or investors, the GSEs have a mandate to serve all markets at all times, which is critical to maintaining liquidity particularly when markets are experiencing financial stress and private capital moves to the sidelines. Exiting receivership includes building capital to successfully operate within a broader housing finance framework, and bipartisan agreement on the proper role of the housing GSEs and the programs necessary to fulfill reasonable and consistent housing goals. Responsible Bank Merger Activity Some community banks have found it helpful to merge with other community banks to be able to spread the significant and escalating costs of regulatory compliance, cybersecurity, technology and innovation to remain highly competitive. Restrictive bank merger legislation or regulations should not apply to community banks. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Insure) Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts Too-Big-To-Not-Insure The 2023 failures of Silicon Valley Bank and Signature Bank revealed that policymakers have created a new category of very large banks - Too-Big-To-Not-Insure (although they will fail) because the FDIC decided to insure 100% of the uninsured deposits of these two failed banks. There must be accountability by both the banks and the regulators for their respective failures. In the future, if systemically important financial institutions (SIFIs) cause losses to the DIF then SIFIs should be responsible for reimbursing the DIF for all the losses they created. Too-Big-To-Fail The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 1799 the Threshold Modernization Act (All Sections) regarding thresholds for currency transaction reporting and Suspicious Activity Reporting (SAR) (House) H.R. 7056 the Community Bank Tailoring Act (All Sections) regarding indexing various asset-based and bank-regulatory reporting thresholds o nominal GDP for community banks (House) H.R. 6955 the Main Street Capital Access Act (All Sections) regarding regulatory fairness, transparency and right-sizing; promoting healthy, growing, and competitive banking industry; and improving access o funding and capital for small to mid-sized banks (House) H.R. 6644 the Housing for the 21st Century Act (Title VI) regarding he inclusion of FDIC modernizing insurance and reciprocal deposit rules, targeted regulatory and examination relief, lowering compliance costs, encouraging the formation of new community banks, and strengthen Minority Depository Institutions (MDIs) (House and Senate) S. 2651 or the ROAD Act which is the 21st Century ROAD to Housing Act regarding the inclusion of the provisions in H.R. 6644 (Housing for the 21st Century Act (Title VI) (House and Senate) H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Letters - Comment Letter to the FDIC regarding PayPal Holdings, Inc. application to the FDIC for deposit insurance for PayPal Bank (FDIC) Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71 (IRS) Comment Letter to the OCC, FDIC and Federal Reserve regarding Notice of Proposed Rulemaking: Regulatory Capital Rule: Revisions to the Community Bank Leverage Ratio Framework - Docket ID OCC-2025-0141, Federal Reserve Docket No. R-1876 and RIN 7100-AH08, and FDIC RIN 3064-AG17 (OCC, FDIC and Federal Reserve) Comment Letter to the Federal Reserve regarding Request for Information and Comment on Reserve Board Payment Account Prototype - Docket No. OP-1877 (aka Fed skinny payment accounts) (Federal Reserve) Comment Letter to the Federal Reserve regarding Request for Information and Comments on the Future of the Federal Reserve Banks Check Services - Docket No. OP-1874 (Federal Reserve) Comment Letter to the OCC regarding Notice of Proposed Rulemaking: Revised Guidelines - OCC Guidelines Establishing Heightened Standards for Certain Large Insured National Banks, Insured Federal Savings Associations, and Insured Federal Branches; Technical Amendments - Docket ID OCC-2025-0207 (OCC) Action Alerts - Action Alert - Urge Your Representative to Support Community Bank Regulatory Relief (House) (See H.R. 6644 Housing for the 21st Century Act above) Miscellaneous - Potential House field hearing on financial fraud (House) Approval of application for Kraken master account with the Federal Reserve (House) EGRPRA Outreach Meeting presentation on March 26, 2026, regarding de novos, particularly newly chartered community banks (OCC, FDIC, Federal Reserve)","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":54,"name":"Federal Deposit Insurance Corporation (FDIC)"},{"id":62,"name":"Federal Reserve System"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":183,"name":"Office of the Comptroller of the Currency (OCC)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"FIN","general_issue_code_display":"Financial Institutions/Investments/Securities","description":"CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. Legitimate Bank Service Charges and Fees are Not Hidden, Exploitive and Junk Fees and Necessary Consumer Financial Responsibility There have been misguided characterizations that community bank service charges and fees are exploitive, unfair and even unlawful. What some have disparaging called Junk fees are bank fees and service charges that are justified, disclosed, and accepted by the consumers who utilize bank products and services. CBAI does not support practices that abuse consumers, but policymakers must accept the position that it is the consumers responsibility to maintain a positive deposit account balance and make their debt payments in a timely manner. It is wrong for policymakers to excuse irresponsible consumer financial behavior and doing so may encourage unacceptable behavior. Realistic Perspective on Financial Inclusion CBAI strongly supports financial inclusion and believes every responsible and able consumer and business should have a banking relationship with their local community bank. There is indisputable proof that the banking industry excels at serving the banking needs of American households. CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the role of federal, state or governments to provide banking services. Governments can assist the private sector in financial inclusion through incentives to promote community banks offering basic accounts and small-dollar consumer loans, especially to low- and middle-income consumers, which are those most likely to be unbanked or underbanked. Protecting Consumers by Restricting the Sale of Mortgage Trigger Leads Trigger leads are generated by credit reporting agencies that contact information about consumers applying for residential mortgage loans to mortgage marketers. This practice is permitted but restricted. Our members report that many of these marketing communications fall short of the legal requirements. Trigger leads compromise consumer privacy, create a flood of unwanted (even harassing) solicitations, create confusion and result in complaints. CBAI supports legislation that would restrict credit reporting agencies from selling consumer contact information unless the applicant has opted in to receive these solicitations. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks SBA Direct Lending Community banks and the SBA have a long, beneficial and cooperative private sector/public sector relationship and the SBA has historically not competed with banks in lending to businesses. Community banks are far superior in prudently underwriting and administering commercial lending relationships. The SBA originating and disbursing 7(a) loans will result in credit underwriting lapses which will put billions of taxpayer dollars at risk of loss. CBAI urges policymakers to prohibit the SBA from making direct 7(a) loans or otherwise expanding the institutions beyond well-regulated banks that could originate SBA loans. Postal Banking CBAI believes postal banking is misguided and views any entry by the USPS into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the USPS to develop and offer banking services. Public Banking CBAI believes public banking is misguided and views any entry by federal, state or local governments into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the government to offer banking services. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Small Business Data Collection A Final Rule was published in March of 2023. The Final Rule was flawed because it exempted too few financial institutions and set the revenue threshold so high that it now encompasses too many businesses, in addition to raising privacy and other concerns. There have been legal challenges to the Final Rule. CBAI supports the reasonable implementation of this reporting requirement and opposed efforts by Farm Credit to exempt its lenders. Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Reporting Beneficial Ownership Information CBAI supports shifting the burden of collecting the BOI of community bank accountholders to the Financial Crimes Enforcement Network (FinCEN). The current requirement is flawed because it does not relieve community banks from this burden. There have been legal challenges to the reporting requirements. CBAI supports making FinCEN the sole repository of BOI and relieving community banks from this burden. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Closing the Industrial Loan Company (ILC) Regulatory Loophole CBAI has consistently supported the long-standing American policy of prohibiting the mixing of banking and commerce, which ILCs represent, because of the risks they pose to the financial system, the FDICs DIF, our economy, consumers and American taxpayers. The risk posed by ILCs, particularly large technology and ecommerce giants, is a regulatory loophole that allows their holding companies to escape from consolidated federal supervision and regulation. This loophole must be closed. Appropriate Regulation of Fintechs and Innovations in Financial Services The pace of innovation in financial services has been accelerating. Many of these new services are offered by financial technology companies - better known as fintechs. Financial innovation presents community banks with challenges and opportunities. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose unreasonable requirements on them, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. Prescriptive and Intrusive FDIC Corporate Governance Guidelines In 2023, the FDIC proposed new corporate governance and risk management guidelines. Although the guidelines only apply to covered institutions with $10 billion or more in assets, these overly prescriptive guidelines apply the same set of standards to larger community banks as they do to the nations largest banks. These guidelines would make it even more difficult to attract new directors, particularly those in rural areas. Harmful Climate Risk Regulations Community bankers high-contact and relationship-based lending model ensures that controls are in place to monitor climate risks on an ongoing basis. CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Consumer Financial Protection Bureau (CFPB) Reform and Exemptions for Community Banks CFPBs regulations must provide community banks with the flexibility to meet the needs of their customers - not a one-size-fits-all approach. They must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. In reforming the CFPB, the single director governance should be replaced by a five-member board or commission. A broader definition of firms that grant credit should be subject to the CFPB rules, and they should be robustly supervised and examined. The focus of any enhanced regulation of financial products should be on the largest banks and financial firms, the unregulated shadow financial industry, and fintechs - not community banks. De Novo Community Bank Formation, the Dual Banking System, and Charter Choice The chartering of many newly chartered (de novo) community banks is vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of continued banking industry consolidation. Hand in hand with renewed de novo bank formation is the importance of maintaining the dual banking system, where chartering and supervision are divided between the federal government and the states, and where the federal government supervision and regulation is divided between the Federal Reserve, Office of Comptroller of the Currency, and the Federal Deposit Insurance Corporation. Community banks should be able to choose the banking charter and associated prudential regulator that best fits their unique needs and business model. Sound Principles for Housing Government Sponsored Entity (GSE) Reform Reforms in government support for housing finance remain important to the future of the housing market and the U.S. economy. Unlike other private aggregators or investors, the GSEs have a mandate to serve all markets at all times, which is critical to maintaining liquidity particularly when markets are experiencing financial stress and private capital moves to the sidelines. Exiting receivership includes building capital to successfully operate within a broader housing finance framework, and bipartisan agreement on the proper role of the housing GSEs and the programs necessary to fulfill reasonable and consistent housing goals. Responsible Bank Merger Activity Some community banks have found it helpful to merge with other community banks to be able to spread the significant and escalating costs of regulatory compliance, cybersecurity, technology and innovation to remain highly competitive. Restrictive bank merger legislation or regulations should not apply to community banks. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Insure) Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts Too-Big-To-Not-Insure The 2023 failures of Silicon Valley Bank and Signature Bank revealed that policymakers have created a new category of very large banks - Too-Big-To-Not-Insure (although they will fail) because the FDIC decided to insure 100% of the uninsured deposits of these two failed banks. There must be accountability by both the banks and the regulators for their respective failures. In the future, if systemically important financial institutions (SIFIs) cause losses to the DIF then SIFIs should be responsible for reimbursing the DIF for all the losses they created. Too-Big-To-Fail The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 1799 the Threshold Modernization Act (All Sections) regarding thresholds for currency transaction reporting and Suspicious Activity Reporting (SAR) (House) H.R. 7056 the Community Bank Tailoring Act (All Sections) regarding indexing various asset-based and bank-regulatory reporting thresholds o nominal GDP for community banks (House) H.R. 6955 the Main Street Capital Access Act (All Sections) regarding regulatory fairness, transparency and right-sizing; promoting healthy, growing, and competitive banking industry; and improving access o funding and capital for small to mid-sized banks (House) H.R. 6644 the Housing for the 21st Century Act (Title VI) regarding he inclusion of FDIC modernizing insurance and reciprocal deposit rules, targeted regulatory and examination relief, lowering compliance costs, encouraging the formation of new community banks, and strengthen Minority Depository Institutions (MDIs) (House and Senate) S. 2651 or the ROAD Act which is the 21st Century ROAD to Housing Act regarding the inclusion of the provisions in H.R. 6644 (Housing for the 21st Century Act (Title VI) (House and Senate) H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Letters - Comment Letter to the FDIC regarding PayPal Holdings, Inc. application to the FDIC for deposit insurance for PayPal Bank (FDIC) Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71 (IRS) Comment Letter to the OCC, FDIC and Federal Reserve regarding Notice of Proposed Rulemaking: Regulatory Capital Rule: Revisions to the Community Bank Leverage Ratio Framework - Docket ID OCC-2025-0141, Federal Reserve Docket No. R-1876 and RIN 7100-AH08, and FDIC RIN 3064-AG17 (OCC, FDIC and Federal Reserve) Comment Letter to the Federal Reserve regarding Request for Information and Comment on Reserve Board Payment Account Prototype - Docket No. OP-1877 (aka Fed skinny payment accounts) (Federal Reserve) Comment Letter to the Federal Reserve regarding Request for Information and Comments on the Future of the Federal Reserve Banks Check Services - Docket No. OP-1874 (Federal Reserve) Comment Letter to the OCC regarding Notice of Proposed Rulemaking: Revised Guidelines - OCC Guidelines Establishing Heightened Standards for Certain Large Insured National Banks, Insured Federal Savings Associations, and Insured Federal Branches; Technical Amendments - Docket ID OCC-2025-0207 (OCC) Action Alerts - Action Alert - Urge Your Representative to Support Community Bank Regulatory Relief (House) (See H.R. 6644 Housing for the 21st Century Act above) Miscellaneous - Potential House field hearing on financial fraud (House) Approval of application for Kraken master account with the Federal Reserve (House) EGRPRA Outreach Meeting presentation on March 26, 2026, regarding de novos, particularly newly chartered community banks (OCC, FDIC, Federal Reserve)","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":54,"name":"Federal Deposit Insurance Corporation (FDIC)"},{"id":62,"name":"Federal Reserve System"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":183,"name":"Office of the Comptroller of the Currency (OCC)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"AGR","general_issue_code_display":"Agriculture","description":"CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Small Business Data Collection A Final Rule was published in March of 2023. The Final Rule was flawed because it exempted too few financial institutions and set the revenue threshold so high that it now encompasses too many businesses, in addition to raising privacy and other concerns. There have been legal challenges to the Final Rule. CBAI supports the reasonable implementation of this reporting requirement and opposed efforts by Farm Credit to exempt its lenders. Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Reporting Beneficial Ownership Information CBAI supports shifting the burden of collecting the BOI of community bank accountholders to the Financial Crimes Enforcement Network (FinCEN). The current requirement is flawed because it does not relieve community banks from this burden. There have been legal challenges to the reporting requirements. CBAI supports making FinCEN the sole repository of BOI and relieving community banks from this burden. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Harmful Climate Risk Regulations Community bankers high-contact and relationship-based lending model ensures that controls are in place to monitor climate risks on an ongoing basis. CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Sound Principles for Housing Government Sponsored Entity (GSE) Reform Reforms in government support for housing finance remain important to the future of the housing market and the U.S. economy. Unlike other private aggregators or investors, the GSEs have a mandate to serve all markets at all times, which is critical to maintaining liquidity particularly when markets are experiencing financial stress and private capital moves to the sidelines. Exiting receivership includes building capital to successfully operate within a broader housing finance framework, and bipartisan agreement on the proper role of the housing GSEs and the programs necessary to fulfill reasonable and consistent housing goals. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 6644 the Housing for the 21st Century Act (Title VI) regarding he inclusion of FDIC modernizing insurance and reciprocal deposit rules, targeted regulatory and examination relief, lowering compliance costs, encouraging the formation of new community banks, and strengthen Minority Depository Institutions (MDIs) (House) S. 2651 or the ROAD Act which is the 21st Century ROAD to Housing Act regarding the inclusion of the provisions in H.R. 6644 (Housing for the 21st Century Act (Title VI) (House and Senate) H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Letters - Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71 (IRS) Comment Letter to the Federal Reserve regarding Request for Information and Comments on the Future of the Federal Reserve Banks Check Services - Docket No. OP-1874 (Federal Reserve) Action Alerts - None Miscellaneous - Potential House field hearing on financial fraud (House)","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":62,"name":"Federal Reserve System"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"CSP","general_issue_code_display":"Consumer Issues/Safety/Products","description":"CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Legitimate Bank Service Charges and Fees are Not Hidden, Exploitive and Junk Fees and Necessary Consumer Financial Responsibility There have been misguided characterizations that community bank service charges and fees are exploitive, unfair and even unlawful. What some have disparaging called Junk fees are bank fees and service charges that are justified, disclosed, and accepted by the consumers who utilize bank products and services. CBAI does not support practices that abuse consumers, but policymakers must accept the position that it is the consumers responsibility to maintain a positive deposit account balance and make their debt payments in a timely manner. It is wrong for policymakers to excuse irresponsible consumer financial behavior and doing so may encourage unacceptable behavior. Realistic Perspective on Financial Inclusion CBAI strongly supports financial inclusion and believes every responsible and able consumer and business should have a banking relationship with their local community bank. There is indisputable proof that the banking industry excels at serving the banking needs of American households. CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the role of federal, state or governments to provide banking services. Governments can assist the private sector in financial inclusion through incentives to promote community banks offering basic accounts and small-dollar consumer loans, especially to low- and middle-income consumers, which are those most likely to be unbanked or underbanked. Protecting Consumers by Restricting the Sale of Mortgage Trigger Leads Trigger leads are generated by credit reporting agencies that contact information about consumers applying for residential mortgage loans to mortgage marketers. This practice is permitted but restricted. Our members report that many of these marketing communications fall short of the legal requirements. Trigger leads compromise consumer privacy, create a flood of unwanted (even harassing) solicitations, create confusion and result in complaints. CBAI supports legislation that would restrict credit reporting agencies from selling consumer contact information unless the applicant has opted in to receive these solicitations. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks Postal Banking CBAI believes postal banking is misguided and views any entry by the USPS into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the USPS to develop and offer banking services. Public Banking CBAI believes public banking is misguided and views any entry by federal, state or local governments into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the government to offer banking services. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Closing the Industrial Loan Company (ILC) Regulatory Loophole CBAI has consistently supported the long-standing American policy of prohibiting the mixing of banking and commerce, which ILCs represent, because of the risks they pose to the financial system, the FDICs DIF, our economy, consumers and American taxpayers. The risk posed by ILCs, particularly large technology and ecommerce giants, is a regulatory loophole that allows their holding companies to escape from consolidated federal supervision and regulation. This loophole must be closed. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Consumer Financial Protection Bureau (CFPB) Reform and Exemptions for Community Banks CFPBs regulations must provide community banks with the flexibility to meet the needs of their customers - not a one-size-fits-all approach. They must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. In reforming the CFPB, the single director governance should be replaced by a five-member board or commission. A broader definition of firms that grant credit should be subject to the CFPB rules, and they should be robustly supervised and examined. The focus of any enhanced regulation of financial products should be on the largest banks and financial firms, the unregulated shadow financial industry, and fintechs - not community banks. Sound Principles for Housing Government Sponsored Entity (GSE) Reform Reforms in government support for housing finance remain important to the future of the housing market and the U.S. economy. Unlike other private aggregators or investors, the GSEs have a mandate to serve all markets at all times, which is critical to maintaining liquidity particularly when markets are experiencing financial stress and private capital moves to the sidelines. Exiting receivership includes building capital to successfully operate within a broader housing finance framework, and bipartisan agreement on the proper role of the housing GSEs and the programs necessary to fulfill reasonable and consistent housing goals. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Letters - Comment Letter to the FDIC regarding PayPal Holdings, Inc. application to the FDIC for deposit insurance for PayPal Bank (FDIC) Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71 (IRS) Comment Letter to the Federal Reserve regarding Request for Information and Comments on the Future of the Federal Reserve Banks Check Services - Docket No. OP-1874 (Federal Reserve) Action Alerts - None Miscellaneous - Potential House field hearing on financial fraud (House) Approval of application for Kraken master account with the Federal Reserve (House)","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":54,"name":"Federal Deposit Insurance Corporation (FDIC)"},{"id":62,"name":"Federal Reserve System"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"SMB","general_issue_code_display":"Small Business","description":"CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks SBA Direct Lending Community banks and the SBA have a long, beneficial and cooperative private sector/public sector relationship and the SBA has historically not competed with banks in lending to businesses. Community banks are far superior in prudently underwriting and administering commercial lending relationships. The SBA originating and disbursing 7(a) loans will result in credit underwriting lapses which will put billions of taxpayer dollars at risk of loss. CBAI urges policymakers to prohibit the SBA from making direct 7(a) loans or otherwise expanding the institutions beyond well-regulated banks that could originate SBA loans. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Small Business Data Collection A Final Rule was published in March of 2023. The Final Rule was flawed because it exempted too few financial institutions and set the revenue threshold so high that it now encompasses too many businesses, in addition to raising privacy and other concerns. There have been legal challenges to the Final Rule. CBAI supports the reasonable implementation of this reporting requirement and opposed efforts by Farm Credit to exempt its lenders. Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Reporting Beneficial Ownership Information CBAI supports shifting the burden of collecting the BOI of community bank accountholders to the Financial Crimes Enforcement Network (FinCEN). The current requirement is flawed because it does not relieve community banks from this burden. There have been legal challenges to the reporting requirements. CBAI supports making FinCEN the sole repository of BOI and relieving community banks from this burden. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Harmful Climate Risk Regulations Community bankers high-contact and relationship-based lending model ensures that controls are in place to monitor climate risks on an ongoing basis. CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Consumer Financial Protection Bureau (CFPB) Reform and Exemptions for Community Banks CFPBs regulations must provide community banks with the flexibility to meet the needs of their customers - not a one-size-fits-all approach. They must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. In reforming the CFPB, the single director governance should be replaced by a five-member board or commission. A broader definition of firms that grant credit should be subject to the CFPB rules, and they should be robustly supervised and examined. The focus of any enhanced regulation of financial products should be on the largest banks and financial firms, the unregulated shadow financial industry, and fintechs - not community banks. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Action Alerts - None Letters - Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71 (IRS) Comment Letter to the Federal Reserve regarding Request for Information and Comments on the Future of the Federal Reserve Banks Check Services - Docket No. OP-1874 (Federal Reserve) Miscellaneous - Potential House field hearing on financial fraud (House)","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":62,"name":"Federal Reserve System"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"TAX","general_issue_code_display":"Taxation/Internal Revenue Code","description":"CBAI Federal Policy Priorities - Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Letters - Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71(IRS) Action Alerts - None Miscellaneous - None","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"ECN","general_issue_code_display":"Economics/Economic Development","description":"CBAI Federal Policy Priorities - Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 6644 the Housing for the 21st Century Act (Title VI) regarding the inclusion of FDIC modernizing insurance and reciprocal deposit rules, targeted regulatory and examination relief, lowering compliance costs, encouraging the formation of new community banks, and strengthen Minority Depository Institutions (MDIs) (House and Senate) S. 2651 or the ROAD Act which is the 21st Century ROAD to Housing Act regarding the inclusion of the provisions in H.R. 6644 (Housing for the 21st Century Act (Title VI) (House and Senate) H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Letters - Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71 (IRS) Comment Letter to the Federal Reserve regarding Request for Information and Comments on the Future of the Federal Reserve Banks Check Services - Docket No. OP-1874 (Federal Reserve) Action Alerts - Action Alert - Urge Your Representative to Support Community Bank Regulatory Relief (House) (See H.R. 6644 Housing for the 21st Century Act above) Miscellaneous - None","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":62,"name":"Federal Reserve System"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":1,"name":"SENATE"}]}],"conviction_disclosures":[],"foreign_entities":[],"affiliated_organizations":[]},{"url":"https://lda.gov/api/v1/filings/8c041376-c992-457a-94a7-eb83e0dd4f41/","filing_uuid":"8c041376-c992-457a-94a7-eb83e0dd4f41","filing_type":"Q1","filing_type_display":"1st Quarter - Report","filing_year":2026,"filing_period":"first_quarter","filing_period_display":"1st Quarter (Jan 1 - Mar 31)","filing_document_url":"https://lda.gov/filings/public/filing/8c041376-c992-457a-94a7-eb83e0dd4f41/print/","filing_document_content_type":"text/html","income":null,"expenses":"65000.00","expenses_method":"A","expenses_method_display":"A","posted_by_name":"David G Schroeder","dt_posted":"2026-04-10T15:38:54-04:00","termination_date":null,"registrant_country":"United States of America","registrant_ppb_country":null,"registrant_address_1":"901 Community Drive","registrant_address_2":null,"registrant_different_address":false,"registrant_city":"Springfield","registrant_state":"IL","registrant_zip":"62703","registrant":{"id":400531588,"url":"https://lda.gov/api/v1/registrants/400531588/","house_registrant_id":null,"name":"COMMUNITY BANKERS ASSOCIATION OF ILLINOIS","description":"Trade association representing Illinois' community banks and thrifts","address_1":"901 Community Drive","address_2":null,"address_3":null,"address_4":null,"city":"Springfield","state":"IL","state_display":"Illinois","zip":"62703","country":"US","country_display":"United States of America","ppb_country":"US","ppb_country_display":"United States of America","contact_name":"DAVID G. SCHROEDER","contact_telephone":"+1 847-909-8341","dt_updated":"2026-07-28T17:21:17.493355-04:00"},"client":{"id":192301,"url":"https://lda.gov/api/v1/clients/192301/","client_id":12,"name":"COMMUNITY BANKERS ASSOCIATION OF ILLINOIS","general_description":null,"client_government_entity":false,"client_self_select":true,"state":"IL","state_display":"Illinois","country":"US","country_display":"United States of America","ppb_state":"IL","ppb_state_display":"Illinois","ppb_country":"US","ppb_country_display":"United States of America","effective_date":"2010-01-01"},"lobbying_activities":[{"general_issue_code":"BAN","general_issue_code_display":"Banking","description":"CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. Legitimate Bank Service Charges and Fees are Not Hidden, Exploitive and Junk Fees and Necessary Consumer Financial Responsibility There have been misguided characterizations that community bank service charges and fees are exploitive, unfair and even unlawful. What some have disparaging called Junk fees are bank fees and service charges that are justified, disclosed, and accepted by the consumers who utilize bank products and services. CBAI does not support practices that abuse consumers, but policymakers must accept the position that it is the consumers responsibility to maintain a positive deposit account balance and make their debt payments in a timely manner. It is wrong for policymakers to excuse irresponsible consumer financial behavior and doing so may encourage unacceptable behavior. Realistic Perspective on Financial Inclusion CBAI strongly supports financial inclusion and believes every responsible and able consumer and business should have a banking relationship with their local community bank. There is indisputable proof that the banking industry excels at serving the banking needs of American households. CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the role of federal, state or governments to provide banking services. Governments can assist the private sector in financial inclusion through incentives to promote community banks offering basic accounts and small-dollar consumer loans, especially to low- and middle-income consumers, which are those most likely to be unbanked or underbanked. Protecting Consumers by Restricting the Sale of Mortgage Trigger Leads Trigger leads are generated by credit reporting agencies that contact information about consumers applying for residential mortgage loans to mortgage marketers. This practice is permitted but restricted. Our members report that many of these marketing communications fall short of the legal requirements. Trigger leads compromise consumer privacy, create a flood of unwanted (even harassing) solicitations, create confusion and result in complaints. CBAI supports legislation that would restrict credit reporting agencies from selling consumer contact information unless the applicant has opted in to receive these solicitations. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks SBA Direct Lending Community banks and the SBA have a long, beneficial and cooperative private sector/public sector relationship and the SBA has historically not competed with banks in lending to businesses. Community banks are far superior in prudently underwriting and administering commercial lending relationships. The SBA originating and disbursing 7(a) loans will result in credit underwriting lapses which will put billions of taxpayer dollars at risk of loss. CBAI urges policymakers to prohibit the SBA from making direct 7(a) loans or otherwise expanding the institutions beyond well-regulated banks that could originate SBA loans. Postal Banking CBAI believes postal banking is misguided and views any entry by the USPS into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the USPS to develop and offer banking services. Public Banking CBAI believes public banking is misguided and views any entry by federal, state or local governments into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the government to offer banking services. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Small Business Data Collection A Final Rule was published in March of 2023. The Final Rule was flawed because it exempted too few financial institutions and set the revenue threshold so high that it now encompasses too many businesses, in addition to raising privacy and other concerns. There have been legal challenges to the Final Rule. CBAI supports the reasonable implementation of this reporting requirement and opposed efforts by Farm Credit to exempt its lenders. Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Reporting Beneficial Ownership Information CBAI supports shifting the burden of collecting the BOI of community bank accountholders to the Financial Crimes Enforcement Network (FinCEN). The current requirement is flawed because it does not relieve community banks from this burden. There have been legal challenges to the reporting requirements. CBAI supports making FinCEN the sole repository of BOI and relieving community banks from this burden. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Closing the Industrial Loan Company (ILC) Regulatory Loophole CBAI has consistently supported the long-standing American policy of prohibiting the mixing of banking and commerce, which ILCs represent, because of the risks they pose to the financial system, the FDICs DIF, our economy, consumers and American taxpayers. The risk posed by ILCs, particularly large technology and ecommerce giants, is a regulatory loophole that allows their holding companies to escape from consolidated federal supervision and regulation. This loophole must be closed. Appropriate Regulation of Fintechs and Innovations in Financial Services The pace of innovation in financial services has been accelerating. Many of these new services are offered by financial technology companies - better known as fintechs. Financial innovation presents community banks with challenges and opportunities. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose unreasonable requirements on them, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. Prescriptive and Intrusive FDIC Corporate Governance Guidelines In 2023, the FDIC proposed new corporate governance and risk management guidelines. Although the guidelines only apply to covered institutions with $10 billion or more in assets, these overly prescriptive guidelines apply the same set of standards to larger community banks as they do to the nations largest banks. These guidelines would make it even more difficult to attract new directors, particularly those in rural areas. Harmful Climate Risk Regulations Community bankers high-contact and relationship-based lending model ensures that controls are in place to monitor climate risks on an ongoing basis. CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Consumer Financial Protection Bureau (CFPB) Reform and Exemptions for Community Banks CFPBs regulations must provide community banks with the flexibility to meet the needs of their customers - not a one-size-fits-all approach. They must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. In reforming the CFPB, the single director governance should be replaced by a five-member board or commission. A broader definition of firms that grant credit should be subject to the CFPB rules, and they should be robustly supervised and examined. The focus of any enhanced regulation of financial products should be on the largest banks and financial firms, the unregulated shadow financial industry, and fintechs - not community banks. De Novo Community Bank Formation, the Dual Banking System, and Charter Choice The chartering of many newly chartered (de novo) community banks is vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of continued banking industry consolidation. Hand in hand with renewed de novo bank formation is the importance of maintaining the dual banking system, where chartering and supervision are divided between the federal government and the states, and where the federal government supervision and regulation is divided between the Federal Reserve, Office of Comptroller of the Currency, and the Federal Deposit Insurance Corporation. Community banks should be able to choose the banking charter and associated prudential regulator that best fits their unique needs and business model. Sound Principles for Housing Government Sponsored Entity (GSE) Reform Reforms in government support for housing finance remain important to the future of the housing market and the U.S. economy. Unlike other private aggregators or investors, the GSEs have a mandate to serve all markets at all times, which is critical to maintaining liquidity particularly when markets are experiencing financial stress and private capital moves to the sidelines. Exiting receivership includes building capital to successfully operate within a broader housing finance framework, and bipartisan agreement on the proper role of the housing GSEs and the programs necessary to fulfill reasonable and consistent housing goals. Responsible Bank Merger Activity Some community banks have found it helpful to merge with other community banks to be able to spread the significant and escalating costs of regulatory compliance, cybersecurity, technology and innovation to remain highly competitive. Restrictive bank merger legislation or regulations should not apply to community banks. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Insure) Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts Too-Big-To-Not-Insure The 2023 failures of Silicon Valley Bank and Signature Bank revealed that policymakers have created a new category of very large banks - Too-Big-To-Not-Insure (although they will fail) because the FDIC decided to insure 100% of the uninsured deposits of these two failed banks. There must be accountability by both the banks and the regulators for their respective failures. In the future, if systemically important financial institutions (SIFIs) cause losses to the DIF then SIFIs should be responsible for reimbursing the DIF for all the losses they created. Too-Big-To-Fail The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 1799 the Threshold Modernization Act (All Sections) regarding thresholds for currency transaction reporting and Suspicious Activity Reporting (SAR) (House) H.R. 7056 the Community Bank Tailoring Act (All Sections) regarding indexing various asset-based and bank-regulatory reporting thresholds o nominal GDP for community banks (House) H.R. 6955 the Main Street Capital Access Act (All Sections) regarding regulatory fairness, transparency and right-sizing; promoting healthy, growing, and competitive banking industry; and improving access o funding and capital for small to mid-sized banks (House) H.R. 6644 the Housing for the 21st Century Act (Title VI) regarding he inclusion of FDIC modernizing insurance and reciprocal deposit rules, targeted regulatory and examination relief, lowering compliance costs, encouraging the formation of new community banks, and strengthen Minority Depository Institutions (MDIs) (House and Senate) S. 2651 or the ROAD Act which is the 21st Century ROAD to Housing Act regarding the inclusion of the provisions in H.R. 6644 (Housing for the 21st Century Act (Title VI) (House and Senate) H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Letters - Comment Letter to the FDIC regarding PayPal Holdings, Inc. application to the FDIC for deposit insurance for PayPal Bank (FDIC) Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71 (IRS) Comment Letter to the OCC, FDIC and Federal Reserve regarding Notice of Proposed Rulemaking: Regulatory Capital Rule: Revisions to the Community Bank Leverage Ratio Framework - Docket ID OCC-2025-0141, Federal Reserve Docket No. R-1876 and RIN 7100-AH08, and FDIC RIN 3064-AG17 (OCC, FDIC and Federal Reserve) Comment Letter to the Federal Reserve regarding Request for Information and Comment on Reserve Board Payment Account Prototype - Docket No. OP-1877 (aka Fed skinny payment accounts) (Federal Reserve) Comment Letter to the Federal Reserve regarding Request for Information and Comments on the Future of the Federal Reserve Banks Check Services - Docket No. OP-1874 (Federal Reserve) Comment Letter to the OCC regarding Notice of Proposed Rulemaking: Revised Guidelines - OCC Guidelines Establishing Heightened Standards for Certain Large Insured National Banks, Insured Federal Savings Associations, and Insured Federal Branches; Technical Amendments - Docket ID OCC-2025-0207 (OCC) Action Alerts - Action Alert - Urge Your Representative to Support Community Bank Regulatory Relief (House) (See H.R. 6644 Housing for the 21st Century Act above) Miscellaneous - Potential House field hearing on financial fraud (House) Approval of application for Kraken master account with the Federal Reserve (House) EGRPRA Outreach Meeting presentation on March 26, 2026, regarding de novos, particularly newly chartered community banks (OCC, FDIC, Federal Reserve)","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":54,"name":"Federal Deposit Insurance Corporation (FDIC)"},{"id":62,"name":"Federal Reserve System"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":183,"name":"Office of the Comptroller of the Currency (OCC)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"FIN","general_issue_code_display":"Financial Institutions/Investments/Securities","description":"CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. Legitimate Bank Service Charges and Fees are Not Hidden, Exploitive and Junk Fees and Necessary Consumer Financial Responsibility There have been misguided characterizations that community bank service charges and fees are exploitive, unfair and even unlawful. What some have disparaging called Junk fees are bank fees and service charges that are justified, disclosed, and accepted by the consumers who utilize bank products and services. CBAI does not support practices that abuse consumers, but policymakers must accept the position that it is the consumers responsibility to maintain a positive deposit account balance and make their debt payments in a timely manner. It is wrong for policymakers to excuse irresponsible consumer financial behavior and doing so may encourage unacceptable behavior. Realistic Perspective on Financial Inclusion CBAI strongly supports financial inclusion and believes every responsible and able consumer and business should have a banking relationship with their local community bank. There is indisputable proof that the banking industry excels at serving the banking needs of American households. CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the role of federal, state or governments to provide banking services. Governments can assist the private sector in financial inclusion through incentives to promote community banks offering basic accounts and small-dollar consumer loans, especially to low- and middle-income consumers, which are those most likely to be unbanked or underbanked. Protecting Consumers by Restricting the Sale of Mortgage Trigger Leads Trigger leads are generated by credit reporting agencies that contact information about consumers applying for residential mortgage loans to mortgage marketers. This practice is permitted but restricted. Our members report that many of these marketing communications fall short of the legal requirements. Trigger leads compromise consumer privacy, create a flood of unwanted (even harassing) solicitations, create confusion and result in complaints. CBAI supports legislation that would restrict credit reporting agencies from selling consumer contact information unless the applicant has opted in to receive these solicitations. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks SBA Direct Lending Community banks and the SBA have a long, beneficial and cooperative private sector/public sector relationship and the SBA has historically not competed with banks in lending to businesses. Community banks are far superior in prudently underwriting and administering commercial lending relationships. The SBA originating and disbursing 7(a) loans will result in credit underwriting lapses which will put billions of taxpayer dollars at risk of loss. CBAI urges policymakers to prohibit the SBA from making direct 7(a) loans or otherwise expanding the institutions beyond well-regulated banks that could originate SBA loans. Postal Banking CBAI believes postal banking is misguided and views any entry by the USPS into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the USPS to develop and offer banking services. Public Banking CBAI believes public banking is misguided and views any entry by federal, state or local governments into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the government to offer banking services. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Small Business Data Collection A Final Rule was published in March of 2023. The Final Rule was flawed because it exempted too few financial institutions and set the revenue threshold so high that it now encompasses too many businesses, in addition to raising privacy and other concerns. There have been legal challenges to the Final Rule. CBAI supports the reasonable implementation of this reporting requirement and opposed efforts by Farm Credit to exempt its lenders. Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Reporting Beneficial Ownership Information CBAI supports shifting the burden of collecting the BOI of community bank accountholders to the Financial Crimes Enforcement Network (FinCEN). The current requirement is flawed because it does not relieve community banks from this burden. There have been legal challenges to the reporting requirements. CBAI supports making FinCEN the sole repository of BOI and relieving community banks from this burden. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Closing the Industrial Loan Company (ILC) Regulatory Loophole CBAI has consistently supported the long-standing American policy of prohibiting the mixing of banking and commerce, which ILCs represent, because of the risks they pose to the financial system, the FDICs DIF, our economy, consumers and American taxpayers. The risk posed by ILCs, particularly large technology and ecommerce giants, is a regulatory loophole that allows their holding companies to escape from consolidated federal supervision and regulation. This loophole must be closed. Appropriate Regulation of Fintechs and Innovations in Financial Services The pace of innovation in financial services has been accelerating. Many of these new services are offered by financial technology companies - better known as fintechs. Financial innovation presents community banks with challenges and opportunities. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose unreasonable requirements on them, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. Prescriptive and Intrusive FDIC Corporate Governance Guidelines In 2023, the FDIC proposed new corporate governance and risk management guidelines. Although the guidelines only apply to covered institutions with $10 billion or more in assets, these overly prescriptive guidelines apply the same set of standards to larger community banks as they do to the nations largest banks. These guidelines would make it even more difficult to attract new directors, particularly those in rural areas. Harmful Climate Risk Regulations Community bankers high-contact and relationship-based lending model ensures that controls are in place to monitor climate risks on an ongoing basis. CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Consumer Financial Protection Bureau (CFPB) Reform and Exemptions for Community Banks CFPBs regulations must provide community banks with the flexibility to meet the needs of their customers - not a one-size-fits-all approach. They must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. In reforming the CFPB, the single director governance should be replaced by a five-member board or commission. A broader definition of firms that grant credit should be subject to the CFPB rules, and they should be robustly supervised and examined. The focus of any enhanced regulation of financial products should be on the largest banks and financial firms, the unregulated shadow financial industry, and fintechs - not community banks. De Novo Community Bank Formation, the Dual Banking System, and Charter Choice The chartering of many newly chartered (de novo) community banks is vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of continued banking industry consolidation. Hand in hand with renewed de novo bank formation is the importance of maintaining the dual banking system, where chartering and supervision are divided between the federal government and the states, and where the federal government supervision and regulation is divided between the Federal Reserve, Office of Comptroller of the Currency, and the Federal Deposit Insurance Corporation. Community banks should be able to choose the banking charter and associated prudential regulator that best fits their unique needs and business model. Sound Principles for Housing Government Sponsored Entity (GSE) Reform Reforms in government support for housing finance remain important to the future of the housing market and the U.S. economy. Unlike other private aggregators or investors, the GSEs have a mandate to serve all markets at all times, which is critical to maintaining liquidity particularly when markets are experiencing financial stress and private capital moves to the sidelines. Exiting receivership includes building capital to successfully operate within a broader housing finance framework, and bipartisan agreement on the proper role of the housing GSEs and the programs necessary to fulfill reasonable and consistent housing goals. Responsible Bank Merger Activity Some community banks have found it helpful to merge with other community banks to be able to spread the significant and escalating costs of regulatory compliance, cybersecurity, technology and innovation to remain highly competitive. Restrictive bank merger legislation or regulations should not apply to community banks. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Insure) Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts Too-Big-To-Not-Insure The 2023 failures of Silicon Valley Bank and Signature Bank revealed that policymakers have created a new category of very large banks - Too-Big-To-Not-Insure (although they will fail) because the FDIC decided to insure 100% of the uninsured deposits of these two failed banks. There must be accountability by both the banks and the regulators for their respective failures. In the future, if systemically important financial institutions (SIFIs) cause losses to the DIF then SIFIs should be responsible for reimbursing the DIF for all the losses they created. Too-Big-To-Fail The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 1799 the Threshold Modernization Act (All Sections) regarding thresholds for currency transaction reporting and Suspicious Activity Reporting (SAR) (House) H.R. 7056 the Community Bank Tailoring Act (All Sections) regarding indexing various asset-based and bank-regulatory reporting thresholds o nominal GDP for community banks (House) H.R. 6955 the Main Street Capital Access Act (All Sections) regarding regulatory fairness, transparency and right-sizing; promoting healthy, growing, and competitive banking industry; and improving access o funding and capital for small to mid-sized banks (House) H.R. 6644 the Housing for the 21st Century Act (Title VI) regarding he inclusion of FDIC modernizing insurance and reciprocal deposit rules, targeted regulatory and examination relief, lowering compliance costs, encouraging the formation of new community banks, and strengthen Minority Depository Institutions (MDIs) (House and Senate) S. 2651 or the ROAD Act which is the 21st Century ROAD to Housing Act regarding the inclusion of the provisions in H.R. 6644 (Housing for the 21st Century Act (Title VI) (House and Senate) H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Letters - Comment Letter to the FDIC regarding PayPal Holdings, Inc. application to the FDIC for deposit insurance for PayPal Bank (FDIC) Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71 (IRS) Comment Letter to the OCC, FDIC and Federal Reserve regarding Notice of Proposed Rulemaking: Regulatory Capital Rule: Revisions to the Community Bank Leverage Ratio Framework - Docket ID OCC-2025-0141, Federal Reserve Docket No. R-1876 and RIN 7100-AH08, and FDIC RIN 3064-AG17 (OCC, FDIC and Federal Reserve) Comment Letter to the Federal Reserve regarding Request for Information and Comment on Reserve Board Payment Account Prototype - Docket No. OP-1877 (aka Fed skinny payment accounts) (Federal Reserve) Comment Letter to the Federal Reserve regarding Request for Information and Comments on the Future of the Federal Reserve Banks Check Services - Docket No. OP-1874 (Federal Reserve) Comment Letter to the OCC regarding Notice of Proposed Rulemaking: Revised Guidelines - OCC Guidelines Establishing Heightened Standards for Certain Large Insured National Banks, Insured Federal Savings Associations, and Insured Federal Branches; Technical Amendments - Docket ID OCC-2025-0207 (OCC) Action Alerts - Action Alert - Urge Your Representative to Support Community Bank Regulatory Relief (House) (See H.R. 6644 Housing for the 21st Century Act above) Miscellaneous - Potential House field hearing on financial fraud (House) Approval of application for Kraken master account with the Federal Reserve (House) EGRPRA Outreach Meeting presentation on March 26, 2026, regarding de novos, particularly newly chartered community banks (OCC, FDIC, Federal Reserve)","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":54,"name":"Federal Deposit Insurance Corporation (FDIC)"},{"id":62,"name":"Federal Reserve System"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":183,"name":"Office of the Comptroller of the Currency (OCC)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"AGR","general_issue_code_display":"Agriculture","description":"CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Small Business Data Collection A Final Rule was published in March of 2023. The Final Rule was flawed because it exempted too few financial institutions and set the revenue threshold so high that it now encompasses too many businesses, in addition to raising privacy and other concerns. There have been legal challenges to the Final Rule. CBAI supports the reasonable implementation of this reporting requirement and opposed efforts by Farm Credit to exempt its lenders. Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Reporting Beneficial Ownership Information CBAI supports shifting the burden of collecting the BOI of community bank accountholders to the Financial Crimes Enforcement Network (FinCEN). The current requirement is flawed because it does not relieve community banks from this burden. There have been legal challenges to the reporting requirements. CBAI supports making FinCEN the sole repository of BOI and relieving community banks from this burden. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Harmful Climate Risk Regulations Community bankers high-contact and relationship-based lending model ensures that controls are in place to monitor climate risks on an ongoing basis. CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Sound Principles for Housing Government Sponsored Entity (GSE) Reform Reforms in government support for housing finance remain important to the future of the housing market and the U.S. economy. Unlike other private aggregators or investors, the GSEs have a mandate to serve all markets at all times, which is critical to maintaining liquidity particularly when markets are experiencing financial stress and private capital moves to the sidelines. Exiting receivership includes building capital to successfully operate within a broader housing finance framework, and bipartisan agreement on the proper role of the housing GSEs and the programs necessary to fulfill reasonable and consistent housing goals. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 6644 the Housing for the 21st Century Act (Title VI) regarding he inclusion of FDIC modernizing insurance and reciprocal deposit rules, targeted regulatory and examination relief, lowering compliance costs, encouraging the formation of new community banks, and strengthen Minority Depository Institutions (MDIs) (House) S. 2651 or the ROAD Act which is the 21st Century ROAD to Housing Act regarding the inclusion of the provisions in H.R. 6644 (Housing for the 21st Century Act (Title VI) (House and Senate) H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Letters - Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71 (IRS) Comment Letter to the Federal Reserve regarding Request for Information and Comments on the Future of the Federal Reserve Banks Check Services - Docket No. OP-1874 (Federal Reserve) Action Alerts - None Miscellaneous - Potential House field hearing on financial fraud (House)","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":62,"name":"Federal Reserve System"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"CSP","general_issue_code_display":"Consumer Issues/Safety/Products","description":"CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Legitimate Bank Service Charges and Fees are Not Hidden, Exploitive and Junk Fees and Necessary Consumer Financial Responsibility There have been misguided characterizations that community bank service charges and fees are exploitive, unfair and even unlawful. What some have disparaging called Junk fees are bank fees and service charges that are justified, disclosed, and accepted by the consumers who utilize bank products and services. CBAI does not support practices that abuse consumers, but policymakers must accept the position that it is the consumers responsibility to maintain a positive deposit account balance and make their debt payments in a timely manner. It is wrong for policymakers to excuse irresponsible consumer financial behavior and doing so may encourage unacceptable behavior. Realistic Perspective on Financial Inclusion CBAI strongly supports financial inclusion and believes every responsible and able consumer and business should have a banking relationship with their local community bank. There is indisputable proof that the banking industry excels at serving the banking needs of American households. CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the role of federal, state or governments to provide banking services. Governments can assist the private sector in financial inclusion through incentives to promote community banks offering basic accounts and small-dollar consumer loans, especially to low- and middle-income consumers, which are those most likely to be unbanked or underbanked. Protecting Consumers by Restricting the Sale of Mortgage Trigger Leads Trigger leads are generated by credit reporting agencies that contact information about consumers applying for residential mortgage loans to mortgage marketers. This practice is permitted but restricted. Our members report that many of these marketing communications fall short of the legal requirements. Trigger leads compromise consumer privacy, create a flood of unwanted (even harassing) solicitations, create confusion and result in complaints. CBAI supports legislation that would restrict credit reporting agencies from selling consumer contact information unless the applicant has opted in to receive these solicitations. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks Postal Banking CBAI believes postal banking is misguided and views any entry by the USPS into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the USPS to develop and offer banking services. Public Banking CBAI believes public banking is misguided and views any entry by federal, state or local governments into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the government to offer banking services. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Closing the Industrial Loan Company (ILC) Regulatory Loophole CBAI has consistently supported the long-standing American policy of prohibiting the mixing of banking and commerce, which ILCs represent, because of the risks they pose to the financial system, the FDICs DIF, our economy, consumers and American taxpayers. The risk posed by ILCs, particularly large technology and ecommerce giants, is a regulatory loophole that allows their holding companies to escape from consolidated federal supervision and regulation. This loophole must be closed. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Consumer Financial Protection Bureau (CFPB) Reform and Exemptions for Community Banks CFPBs regulations must provide community banks with the flexibility to meet the needs of their customers - not a one-size-fits-all approach. They must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. In reforming the CFPB, the single director governance should be replaced by a five-member board or commission. A broader definition of firms that grant credit should be subject to the CFPB rules, and they should be robustly supervised and examined. The focus of any enhanced regulation of financial products should be on the largest banks and financial firms, the unregulated shadow financial industry, and fintechs - not community banks. Sound Principles for Housing Government Sponsored Entity (GSE) Reform Reforms in government support for housing finance remain important to the future of the housing market and the U.S. economy. Unlike other private aggregators or investors, the GSEs have a mandate to serve all markets at all times, which is critical to maintaining liquidity particularly when markets are experiencing financial stress and private capital moves to the sidelines. Exiting receivership includes building capital to successfully operate within a broader housing finance framework, and bipartisan agreement on the proper role of the housing GSEs and the programs necessary to fulfill reasonable and consistent housing goals. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Letters - Comment Letter to the FDIC regarding PayPal Holdings, Inc. application to the FDIC for deposit insurance for PayPal Bank (FDIC) Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71 (IRS) Comment Letter to the Federal Reserve regarding Request for Information and Comments on the Future of the Federal Reserve Banks Check Services - Docket No. OP-1874 (Federal Reserve) Action Alerts - None Miscellaneous - Potential House field hearing on financial fraud (House) Approval of application for Kraken master account with the Federal Reserve (House)","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":54,"name":"Federal Deposit Insurance Corporation (FDIC)"},{"id":62,"name":"Federal Reserve System"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"SMB","general_issue_code_display":"Small Business","description":"CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks SBA Direct Lending Community banks and the SBA have a long, beneficial and cooperative private sector/public sector relationship and the SBA has historically not competed with banks in lending to businesses. Community banks are far superior in prudently underwriting and administering commercial lending relationships. The SBA originating and disbursing 7(a) loans will result in credit underwriting lapses which will put billions of taxpayer dollars at risk of loss. CBAI urges policymakers to prohibit the SBA from making direct 7(a) loans or otherwise expanding the institutions beyond well-regulated banks that could originate SBA loans. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Small Business Data Collection A Final Rule was published in March of 2023. The Final Rule was flawed because it exempted too few financial institutions and set the revenue threshold so high that it now encompasses too many businesses, in addition to raising privacy and other concerns. There have been legal challenges to the Final Rule. CBAI supports the reasonable implementation of this reporting requirement and opposed efforts by Farm Credit to exempt its lenders. Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Reporting Beneficial Ownership Information CBAI supports shifting the burden of collecting the BOI of community bank accountholders to the Financial Crimes Enforcement Network (FinCEN). The current requirement is flawed because it does not relieve community banks from this burden. There have been legal challenges to the reporting requirements. CBAI supports making FinCEN the sole repository of BOI and relieving community banks from this burden. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Harmful Climate Risk Regulations Community bankers high-contact and relationship-based lending model ensures that controls are in place to monitor climate risks on an ongoing basis. CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Consumer Financial Protection Bureau (CFPB) Reform and Exemptions for Community Banks CFPBs regulations must provide community banks with the flexibility to meet the needs of their customers - not a one-size-fits-all approach. They must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. In reforming the CFPB, the single director governance should be replaced by a five-member board or commission. A broader definition of firms that grant credit should be subject to the CFPB rules, and they should be robustly supervised and examined. The focus of any enhanced regulation of financial products should be on the largest banks and financial firms, the unregulated shadow financial industry, and fintechs - not community banks. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Action Alerts - None Letters - Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71 (IRS) Comment Letter to the Federal Reserve regarding Request for Information and Comments on the Future of the Federal Reserve Banks Check Services - Docket No. OP-1874 (Federal Reserve) Miscellaneous - Potential House field hearing on financial fraud (House)","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":62,"name":"Federal Reserve System"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"TAX","general_issue_code_display":"Taxation/Internal Revenue Code","description":"CBAI Federal Policy Priorities - Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Letters - Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71(IRS) Action Alerts - None Miscellaneous - None","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"ECN","general_issue_code_display":"Economics/Economic Development","description":"CBAI Federal Policy Priorities - Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 6644 the Housing for the 21st Century Act (Title VI) regarding the inclusion of FDIC modernizing insurance and reciprocal deposit rules, targeted regulatory and examination relief, lowering compliance costs, encouraging the formation of new community banks, and strengthen Minority Depository Institutions (MDIs) (House and Senate) S. 2651 or the ROAD Act which is the 21st Century ROAD to Housing Act regarding the inclusion of the provisions in H.R. 6644 (Housing for the 21st Century Act (Title VI) (House and Senate) H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Letters - Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71 (IRS) Comment Letter to the Federal Reserve regarding Request for Information and Comments on the Future of the Federal Reserve Banks Check Services - Docket No. OP-1874 (Federal Reserve) Action Alerts - Action Alert - Urge Your Representative to Support Community Bank Regulatory Relief (House) (See H.R. 6644 Housing for the 21st Century Act above) Miscellaneous - None","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":62,"name":"Federal Reserve System"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":1,"name":"SENATE"}]}],"conviction_disclosures":[],"foreign_entities":[],"affiliated_organizations":[]},{"url":"https://lda.gov/api/v1/filings/8c041376-c992-457a-94a7-eb83e0dd4f41/","filing_uuid":"8c041376-c992-457a-94a7-eb83e0dd4f41","filing_type":"Q1","filing_type_display":"1st Quarter - Report","filing_year":2026,"filing_period":"first_quarter","filing_period_display":"1st Quarter (Jan 1 - Mar 31)","filing_document_url":"https://lda.gov/filings/public/filing/8c041376-c992-457a-94a7-eb83e0dd4f41/print/","filing_document_content_type":"text/html","income":null,"expenses":"65000.00","expenses_method":"A","expenses_method_display":"A","posted_by_name":"David G Schroeder","dt_posted":"2026-04-10T15:38:54-04:00","termination_date":null,"registrant_country":"United States of America","registrant_ppb_country":null,"registrant_address_1":"901 Community Drive","registrant_address_2":null,"registrant_different_address":false,"registrant_city":"Springfield","registrant_state":"IL","registrant_zip":"62703","registrant":{"id":400531588,"url":"https://lda.gov/api/v1/registrants/400531588/","house_registrant_id":null,"name":"COMMUNITY BANKERS ASSOCIATION OF ILLINOIS","description":"Trade association representing Illinois' community banks and thrifts","address_1":"901 Community Drive","address_2":null,"address_3":null,"address_4":null,"city":"Springfield","state":"IL","state_display":"Illinois","zip":"62703","country":"US","country_display":"United States of America","ppb_country":"US","ppb_country_display":"United States of America","contact_name":"DAVID G. SCHROEDER","contact_telephone":"+1 847-909-8341","dt_updated":"2026-07-28T17:21:17.493355-04:00"},"client":{"id":192301,"url":"https://lda.gov/api/v1/clients/192301/","client_id":12,"name":"COMMUNITY BANKERS ASSOCIATION OF ILLINOIS","general_description":null,"client_government_entity":false,"client_self_select":true,"state":"IL","state_display":"Illinois","country":"US","country_display":"United States of America","ppb_state":"IL","ppb_state_display":"Illinois","ppb_country":"US","ppb_country_display":"United States of America","effective_date":"2010-01-01"},"lobbying_activities":[{"general_issue_code":"BAN","general_issue_code_display":"Banking","description":"CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. Legitimate Bank Service Charges and Fees are Not Hidden, Exploitive and Junk Fees and Necessary Consumer Financial Responsibility There have been misguided characterizations that community bank service charges and fees are exploitive, unfair and even unlawful. What some have disparaging called Junk fees are bank fees and service charges that are justified, disclosed, and accepted by the consumers who utilize bank products and services. CBAI does not support practices that abuse consumers, but policymakers must accept the position that it is the consumers responsibility to maintain a positive deposit account balance and make their debt payments in a timely manner. It is wrong for policymakers to excuse irresponsible consumer financial behavior and doing so may encourage unacceptable behavior. Realistic Perspective on Financial Inclusion CBAI strongly supports financial inclusion and believes every responsible and able consumer and business should have a banking relationship with their local community bank. There is indisputable proof that the banking industry excels at serving the banking needs of American households. CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the role of federal, state or governments to provide banking services. Governments can assist the private sector in financial inclusion through incentives to promote community banks offering basic accounts and small-dollar consumer loans, especially to low- and middle-income consumers, which are those most likely to be unbanked or underbanked. Protecting Consumers by Restricting the Sale of Mortgage Trigger Leads Trigger leads are generated by credit reporting agencies that contact information about consumers applying for residential mortgage loans to mortgage marketers. This practice is permitted but restricted. Our members report that many of these marketing communications fall short of the legal requirements. Trigger leads compromise consumer privacy, create a flood of unwanted (even harassing) solicitations, create confusion and result in complaints. CBAI supports legislation that would restrict credit reporting agencies from selling consumer contact information unless the applicant has opted in to receive these solicitations. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks SBA Direct Lending Community banks and the SBA have a long, beneficial and cooperative private sector/public sector relationship and the SBA has historically not competed with banks in lending to businesses. Community banks are far superior in prudently underwriting and administering commercial lending relationships. The SBA originating and disbursing 7(a) loans will result in credit underwriting lapses which will put billions of taxpayer dollars at risk of loss. CBAI urges policymakers to prohibit the SBA from making direct 7(a) loans or otherwise expanding the institutions beyond well-regulated banks that could originate SBA loans. Postal Banking CBAI believes postal banking is misguided and views any entry by the USPS into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the USPS to develop and offer banking services. Public Banking CBAI believes public banking is misguided and views any entry by federal, state or local governments into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the government to offer banking services. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Small Business Data Collection A Final Rule was published in March of 2023. The Final Rule was flawed because it exempted too few financial institutions and set the revenue threshold so high that it now encompasses too many businesses, in addition to raising privacy and other concerns. There have been legal challenges to the Final Rule. CBAI supports the reasonable implementation of this reporting requirement and opposed efforts by Farm Credit to exempt its lenders. Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Reporting Beneficial Ownership Information CBAI supports shifting the burden of collecting the BOI of community bank accountholders to the Financial Crimes Enforcement Network (FinCEN). The current requirement is flawed because it does not relieve community banks from this burden. There have been legal challenges to the reporting requirements. CBAI supports making FinCEN the sole repository of BOI and relieving community banks from this burden. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Closing the Industrial Loan Company (ILC) Regulatory Loophole CBAI has consistently supported the long-standing American policy of prohibiting the mixing of banking and commerce, which ILCs represent, because of the risks they pose to the financial system, the FDICs DIF, our economy, consumers and American taxpayers. The risk posed by ILCs, particularly large technology and ecommerce giants, is a regulatory loophole that allows their holding companies to escape from consolidated federal supervision and regulation. This loophole must be closed. Appropriate Regulation of Fintechs and Innovations in Financial Services The pace of innovation in financial services has been accelerating. Many of these new services are offered by financial technology companies - better known as fintechs. Financial innovation presents community banks with challenges and opportunities. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose unreasonable requirements on them, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. Prescriptive and Intrusive FDIC Corporate Governance Guidelines In 2023, the FDIC proposed new corporate governance and risk management guidelines. Although the guidelines only apply to covered institutions with $10 billion or more in assets, these overly prescriptive guidelines apply the same set of standards to larger community banks as they do to the nations largest banks. These guidelines would make it even more difficult to attract new directors, particularly those in rural areas. Harmful Climate Risk Regulations Community bankers high-contact and relationship-based lending model ensures that controls are in place to monitor climate risks on an ongoing basis. CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Consumer Financial Protection Bureau (CFPB) Reform and Exemptions for Community Banks CFPBs regulations must provide community banks with the flexibility to meet the needs of their customers - not a one-size-fits-all approach. They must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. In reforming the CFPB, the single director governance should be replaced by a five-member board or commission. A broader definition of firms that grant credit should be subject to the CFPB rules, and they should be robustly supervised and examined. The focus of any enhanced regulation of financial products should be on the largest banks and financial firms, the unregulated shadow financial industry, and fintechs - not community banks. De Novo Community Bank Formation, the Dual Banking System, and Charter Choice The chartering of many newly chartered (de novo) community banks is vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of continued banking industry consolidation. Hand in hand with renewed de novo bank formation is the importance of maintaining the dual banking system, where chartering and supervision are divided between the federal government and the states, and where the federal government supervision and regulation is divided between the Federal Reserve, Office of Comptroller of the Currency, and the Federal Deposit Insurance Corporation. Community banks should be able to choose the banking charter and associated prudential regulator that best fits their unique needs and business model. Sound Principles for Housing Government Sponsored Entity (GSE) Reform Reforms in government support for housing finance remain important to the future of the housing market and the U.S. economy. Unlike other private aggregators or investors, the GSEs have a mandate to serve all markets at all times, which is critical to maintaining liquidity particularly when markets are experiencing financial stress and private capital moves to the sidelines. Exiting receivership includes building capital to successfully operate within a broader housing finance framework, and bipartisan agreement on the proper role of the housing GSEs and the programs necessary to fulfill reasonable and consistent housing goals. Responsible Bank Merger Activity Some community banks have found it helpful to merge with other community banks to be able to spread the significant and escalating costs of regulatory compliance, cybersecurity, technology and innovation to remain highly competitive. Restrictive bank merger legislation or regulations should not apply to community banks. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Insure) Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts Too-Big-To-Not-Insure The 2023 failures of Silicon Valley Bank and Signature Bank revealed that policymakers have created a new category of very large banks - Too-Big-To-Not-Insure (although they will fail) because the FDIC decided to insure 100% of the uninsured deposits of these two failed banks. There must be accountability by both the banks and the regulators for their respective failures. In the future, if systemically important financial institutions (SIFIs) cause losses to the DIF then SIFIs should be responsible for reimbursing the DIF for all the losses they created. Too-Big-To-Fail The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 1799 the Threshold Modernization Act (All Sections) regarding thresholds for currency transaction reporting and Suspicious Activity Reporting (SAR) (House) H.R. 7056 the Community Bank Tailoring Act (All Sections) regarding indexing various asset-based and bank-regulatory reporting thresholds o nominal GDP for community banks (House) H.R. 6955 the Main Street Capital Access Act (All Sections) regarding regulatory fairness, transparency and right-sizing; promoting healthy, growing, and competitive banking industry; and improving access o funding and capital for small to mid-sized banks (House) H.R. 6644 the Housing for the 21st Century Act (Title VI) regarding he inclusion of FDIC modernizing insurance and reciprocal deposit rules, targeted regulatory and examination relief, lowering compliance costs, encouraging the formation of new community banks, and strengthen Minority Depository Institutions (MDIs) (House and Senate) S. 2651 or the ROAD Act which is the 21st Century ROAD to Housing Act regarding the inclusion of the provisions in H.R. 6644 (Housing for the 21st Century Act (Title VI) (House and Senate) H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Letters - Comment Letter to the FDIC regarding PayPal Holdings, Inc. application to the FDIC for deposit insurance for PayPal Bank (FDIC) Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71 (IRS) Comment Letter to the OCC, FDIC and Federal Reserve regarding Notice of Proposed Rulemaking: Regulatory Capital Rule: Revisions to the Community Bank Leverage Ratio Framework - Docket ID OCC-2025-0141, Federal Reserve Docket No. R-1876 and RIN 7100-AH08, and FDIC RIN 3064-AG17 (OCC, FDIC and Federal Reserve) Comment Letter to the Federal Reserve regarding Request for Information and Comment on Reserve Board Payment Account Prototype - Docket No. OP-1877 (aka Fed skinny payment accounts) (Federal Reserve) Comment Letter to the Federal Reserve regarding Request for Information and Comments on the Future of the Federal Reserve Banks Check Services - Docket No. OP-1874 (Federal Reserve) Comment Letter to the OCC regarding Notice of Proposed Rulemaking: Revised Guidelines - OCC Guidelines Establishing Heightened Standards for Certain Large Insured National Banks, Insured Federal Savings Associations, and Insured Federal Branches; Technical Amendments - Docket ID OCC-2025-0207 (OCC) Action Alerts - Action Alert - Urge Your Representative to Support Community Bank Regulatory Relief (House) (See H.R. 6644 Housing for the 21st Century Act above) Miscellaneous - Potential House field hearing on financial fraud (House) Approval of application for Kraken master account with the Federal Reserve (House) EGRPRA Outreach Meeting presentation on March 26, 2026, regarding de novos, particularly newly chartered community banks (OCC, FDIC, Federal Reserve)","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":54,"name":"Federal Deposit Insurance Corporation (FDIC)"},{"id":62,"name":"Federal Reserve System"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":183,"name":"Office of the Comptroller of the Currency (OCC)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"FIN","general_issue_code_display":"Financial Institutions/Investments/Securities","description":"CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. Legitimate Bank Service Charges and Fees are Not Hidden, Exploitive and Junk Fees and Necessary Consumer Financial Responsibility There have been misguided characterizations that community bank service charges and fees are exploitive, unfair and even unlawful. What some have disparaging called Junk fees are bank fees and service charges that are justified, disclosed, and accepted by the consumers who utilize bank products and services. CBAI does not support practices that abuse consumers, but policymakers must accept the position that it is the consumers responsibility to maintain a positive deposit account balance and make their debt payments in a timely manner. It is wrong for policymakers to excuse irresponsible consumer financial behavior and doing so may encourage unacceptable behavior. Realistic Perspective on Financial Inclusion CBAI strongly supports financial inclusion and believes every responsible and able consumer and business should have a banking relationship with their local community bank. There is indisputable proof that the banking industry excels at serving the banking needs of American households. CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the role of federal, state or governments to provide banking services. Governments can assist the private sector in financial inclusion through incentives to promote community banks offering basic accounts and small-dollar consumer loans, especially to low- and middle-income consumers, which are those most likely to be unbanked or underbanked. Protecting Consumers by Restricting the Sale of Mortgage Trigger Leads Trigger leads are generated by credit reporting agencies that contact information about consumers applying for residential mortgage loans to mortgage marketers. This practice is permitted but restricted. Our members report that many of these marketing communications fall short of the legal requirements. Trigger leads compromise consumer privacy, create a flood of unwanted (even harassing) solicitations, create confusion and result in complaints. CBAI supports legislation that would restrict credit reporting agencies from selling consumer contact information unless the applicant has opted in to receive these solicitations. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks SBA Direct Lending Community banks and the SBA have a long, beneficial and cooperative private sector/public sector relationship and the SBA has historically not competed with banks in lending to businesses. Community banks are far superior in prudently underwriting and administering commercial lending relationships. The SBA originating and disbursing 7(a) loans will result in credit underwriting lapses which will put billions of taxpayer dollars at risk of loss. CBAI urges policymakers to prohibit the SBA from making direct 7(a) loans or otherwise expanding the institutions beyond well-regulated banks that could originate SBA loans. Postal Banking CBAI believes postal banking is misguided and views any entry by the USPS into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the USPS to develop and offer banking services. Public Banking CBAI believes public banking is misguided and views any entry by federal, state or local governments into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the government to offer banking services. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Small Business Data Collection A Final Rule was published in March of 2023. The Final Rule was flawed because it exempted too few financial institutions and set the revenue threshold so high that it now encompasses too many businesses, in addition to raising privacy and other concerns. There have been legal challenges to the Final Rule. CBAI supports the reasonable implementation of this reporting requirement and opposed efforts by Farm Credit to exempt its lenders. Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Reporting Beneficial Ownership Information CBAI supports shifting the burden of collecting the BOI of community bank accountholders to the Financial Crimes Enforcement Network (FinCEN). The current requirement is flawed because it does not relieve community banks from this burden. There have been legal challenges to the reporting requirements. CBAI supports making FinCEN the sole repository of BOI and relieving community banks from this burden. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Closing the Industrial Loan Company (ILC) Regulatory Loophole CBAI has consistently supported the long-standing American policy of prohibiting the mixing of banking and commerce, which ILCs represent, because of the risks they pose to the financial system, the FDICs DIF, our economy, consumers and American taxpayers. The risk posed by ILCs, particularly large technology and ecommerce giants, is a regulatory loophole that allows their holding companies to escape from consolidated federal supervision and regulation. This loophole must be closed. Appropriate Regulation of Fintechs and Innovations in Financial Services The pace of innovation in financial services has been accelerating. Many of these new services are offered by financial technology companies - better known as fintechs. Financial innovation presents community banks with challenges and opportunities. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose unreasonable requirements on them, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. Prescriptive and Intrusive FDIC Corporate Governance Guidelines In 2023, the FDIC proposed new corporate governance and risk management guidelines. Although the guidelines only apply to covered institutions with $10 billion or more in assets, these overly prescriptive guidelines apply the same set of standards to larger community banks as they do to the nations largest banks. These guidelines would make it even more difficult to attract new directors, particularly those in rural areas. Harmful Climate Risk Regulations Community bankers high-contact and relationship-based lending model ensures that controls are in place to monitor climate risks on an ongoing basis. CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Consumer Financial Protection Bureau (CFPB) Reform and Exemptions for Community Banks CFPBs regulations must provide community banks with the flexibility to meet the needs of their customers - not a one-size-fits-all approach. They must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. In reforming the CFPB, the single director governance should be replaced by a five-member board or commission. A broader definition of firms that grant credit should be subject to the CFPB rules, and they should be robustly supervised and examined. The focus of any enhanced regulation of financial products should be on the largest banks and financial firms, the unregulated shadow financial industry, and fintechs - not community banks. De Novo Community Bank Formation, the Dual Banking System, and Charter Choice The chartering of many newly chartered (de novo) community banks is vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of continued banking industry consolidation. Hand in hand with renewed de novo bank formation is the importance of maintaining the dual banking system, where chartering and supervision are divided between the federal government and the states, and where the federal government supervision and regulation is divided between the Federal Reserve, Office of Comptroller of the Currency, and the Federal Deposit Insurance Corporation. Community banks should be able to choose the banking charter and associated prudential regulator that best fits their unique needs and business model. Sound Principles for Housing Government Sponsored Entity (GSE) Reform Reforms in government support for housing finance remain important to the future of the housing market and the U.S. economy. Unlike other private aggregators or investors, the GSEs have a mandate to serve all markets at all times, which is critical to maintaining liquidity particularly when markets are experiencing financial stress and private capital moves to the sidelines. Exiting receivership includes building capital to successfully operate within a broader housing finance framework, and bipartisan agreement on the proper role of the housing GSEs and the programs necessary to fulfill reasonable and consistent housing goals. Responsible Bank Merger Activity Some community banks have found it helpful to merge with other community banks to be able to spread the significant and escalating costs of regulatory compliance, cybersecurity, technology and innovation to remain highly competitive. Restrictive bank merger legislation or regulations should not apply to community banks. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Insure) Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts Too-Big-To-Not-Insure The 2023 failures of Silicon Valley Bank and Signature Bank revealed that policymakers have created a new category of very large banks - Too-Big-To-Not-Insure (although they will fail) because the FDIC decided to insure 100% of the uninsured deposits of these two failed banks. There must be accountability by both the banks and the regulators for their respective failures. In the future, if systemically important financial institutions (SIFIs) cause losses to the DIF then SIFIs should be responsible for reimbursing the DIF for all the losses they created. Too-Big-To-Fail The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 1799 the Threshold Modernization Act (All Sections) regarding thresholds for currency transaction reporting and Suspicious Activity Reporting (SAR) (House) H.R. 7056 the Community Bank Tailoring Act (All Sections) regarding indexing various asset-based and bank-regulatory reporting thresholds o nominal GDP for community banks (House) H.R. 6955 the Main Street Capital Access Act (All Sections) regarding regulatory fairness, transparency and right-sizing; promoting healthy, growing, and competitive banking industry; and improving access o funding and capital for small to mid-sized banks (House) H.R. 6644 the Housing for the 21st Century Act (Title VI) regarding he inclusion of FDIC modernizing insurance and reciprocal deposit rules, targeted regulatory and examination relief, lowering compliance costs, encouraging the formation of new community banks, and strengthen Minority Depository Institutions (MDIs) (House and Senate) S. 2651 or the ROAD Act which is the 21st Century ROAD to Housing Act regarding the inclusion of the provisions in H.R. 6644 (Housing for the 21st Century Act (Title VI) (House and Senate) H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Letters - Comment Letter to the FDIC regarding PayPal Holdings, Inc. application to the FDIC for deposit insurance for PayPal Bank (FDIC) Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71 (IRS) Comment Letter to the OCC, FDIC and Federal Reserve regarding Notice of Proposed Rulemaking: Regulatory Capital Rule: Revisions to the Community Bank Leverage Ratio Framework - Docket ID OCC-2025-0141, Federal Reserve Docket No. R-1876 and RIN 7100-AH08, and FDIC RIN 3064-AG17 (OCC, FDIC and Federal Reserve) Comment Letter to the Federal Reserve regarding Request for Information and Comment on Reserve Board Payment Account Prototype - Docket No. OP-1877 (aka Fed skinny payment accounts) (Federal Reserve) Comment Letter to the Federal Reserve regarding Request for Information and Comments on the Future of the Federal Reserve Banks Check Services - Docket No. OP-1874 (Federal Reserve) Comment Letter to the OCC regarding Notice of Proposed Rulemaking: Revised Guidelines - OCC Guidelines Establishing Heightened Standards for Certain Large Insured National Banks, Insured Federal Savings Associations, and Insured Federal Branches; Technical Amendments - Docket ID OCC-2025-0207 (OCC) Action Alerts - Action Alert - Urge Your Representative to Support Community Bank Regulatory Relief (House) (See H.R. 6644 Housing for the 21st Century Act above) Miscellaneous - Potential House field hearing on financial fraud (House) Approval of application for Kraken master account with the Federal Reserve (House) EGRPRA Outreach Meeting presentation on March 26, 2026, regarding de novos, particularly newly chartered community banks (OCC, FDIC, Federal Reserve)","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":54,"name":"Federal Deposit Insurance Corporation (FDIC)"},{"id":62,"name":"Federal Reserve System"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":183,"name":"Office of the Comptroller of the Currency (OCC)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"AGR","general_issue_code_display":"Agriculture","description":"CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Small Business Data Collection A Final Rule was published in March of 2023. The Final Rule was flawed because it exempted too few financial institutions and set the revenue threshold so high that it now encompasses too many businesses, in addition to raising privacy and other concerns. There have been legal challenges to the Final Rule. CBAI supports the reasonable implementation of this reporting requirement and opposed efforts by Farm Credit to exempt its lenders. Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Reporting Beneficial Ownership Information CBAI supports shifting the burden of collecting the BOI of community bank accountholders to the Financial Crimes Enforcement Network (FinCEN). The current requirement is flawed because it does not relieve community banks from this burden. There have been legal challenges to the reporting requirements. CBAI supports making FinCEN the sole repository of BOI and relieving community banks from this burden. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Harmful Climate Risk Regulations Community bankers high-contact and relationship-based lending model ensures that controls are in place to monitor climate risks on an ongoing basis. CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Sound Principles for Housing Government Sponsored Entity (GSE) Reform Reforms in government support for housing finance remain important to the future of the housing market and the U.S. economy. Unlike other private aggregators or investors, the GSEs have a mandate to serve all markets at all times, which is critical to maintaining liquidity particularly when markets are experiencing financial stress and private capital moves to the sidelines. Exiting receivership includes building capital to successfully operate within a broader housing finance framework, and bipartisan agreement on the proper role of the housing GSEs and the programs necessary to fulfill reasonable and consistent housing goals. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 6644 the Housing for the 21st Century Act (Title VI) regarding he inclusion of FDIC modernizing insurance and reciprocal deposit rules, targeted regulatory and examination relief, lowering compliance costs, encouraging the formation of new community banks, and strengthen Minority Depository Institutions (MDIs) (House) S. 2651 or the ROAD Act which is the 21st Century ROAD to Housing Act regarding the inclusion of the provisions in H.R. 6644 (Housing for the 21st Century Act (Title VI) (House and Senate) H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Letters - Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71 (IRS) Comment Letter to the Federal Reserve regarding Request for Information and Comments on the Future of the Federal Reserve Banks Check Services - Docket No. OP-1874 (Federal Reserve) Action Alerts - None Miscellaneous - Potential House field hearing on financial fraud (House)","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":62,"name":"Federal Reserve System"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"CSP","general_issue_code_display":"Consumer Issues/Safety/Products","description":"CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Legitimate Bank Service Charges and Fees are Not Hidden, Exploitive and Junk Fees and Necessary Consumer Financial Responsibility There have been misguided characterizations that community bank service charges and fees are exploitive, unfair and even unlawful. What some have disparaging called Junk fees are bank fees and service charges that are justified, disclosed, and accepted by the consumers who utilize bank products and services. CBAI does not support practices that abuse consumers, but policymakers must accept the position that it is the consumers responsibility to maintain a positive deposit account balance and make their debt payments in a timely manner. It is wrong for policymakers to excuse irresponsible consumer financial behavior and doing so may encourage unacceptable behavior. Realistic Perspective on Financial Inclusion CBAI strongly supports financial inclusion and believes every responsible and able consumer and business should have a banking relationship with their local community bank. There is indisputable proof that the banking industry excels at serving the banking needs of American households. CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the role of federal, state or governments to provide banking services. Governments can assist the private sector in financial inclusion through incentives to promote community banks offering basic accounts and small-dollar consumer loans, especially to low- and middle-income consumers, which are those most likely to be unbanked or underbanked. Protecting Consumers by Restricting the Sale of Mortgage Trigger Leads Trigger leads are generated by credit reporting agencies that contact information about consumers applying for residential mortgage loans to mortgage marketers. This practice is permitted but restricted. Our members report that many of these marketing communications fall short of the legal requirements. Trigger leads compromise consumer privacy, create a flood of unwanted (even harassing) solicitations, create confusion and result in complaints. CBAI supports legislation that would restrict credit reporting agencies from selling consumer contact information unless the applicant has opted in to receive these solicitations. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks Postal Banking CBAI believes postal banking is misguided and views any entry by the USPS into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the USPS to develop and offer banking services. Public Banking CBAI believes public banking is misguided and views any entry by federal, state or local governments into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the government to offer banking services. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Closing the Industrial Loan Company (ILC) Regulatory Loophole CBAI has consistently supported the long-standing American policy of prohibiting the mixing of banking and commerce, which ILCs represent, because of the risks they pose to the financial system, the FDICs DIF, our economy, consumers and American taxpayers. The risk posed by ILCs, particularly large technology and ecommerce giants, is a regulatory loophole that allows their holding companies to escape from consolidated federal supervision and regulation. This loophole must be closed. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Consumer Financial Protection Bureau (CFPB) Reform and Exemptions for Community Banks CFPBs regulations must provide community banks with the flexibility to meet the needs of their customers - not a one-size-fits-all approach. They must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. In reforming the CFPB, the single director governance should be replaced by a five-member board or commission. A broader definition of firms that grant credit should be subject to the CFPB rules, and they should be robustly supervised and examined. The focus of any enhanced regulation of financial products should be on the largest banks and financial firms, the unregulated shadow financial industry, and fintechs - not community banks. Sound Principles for Housing Government Sponsored Entity (GSE) Reform Reforms in government support for housing finance remain important to the future of the housing market and the U.S. economy. Unlike other private aggregators or investors, the GSEs have a mandate to serve all markets at all times, which is critical to maintaining liquidity particularly when markets are experiencing financial stress and private capital moves to the sidelines. Exiting receivership includes building capital to successfully operate within a broader housing finance framework, and bipartisan agreement on the proper role of the housing GSEs and the programs necessary to fulfill reasonable and consistent housing goals. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Letters - Comment Letter to the FDIC regarding PayPal Holdings, Inc. application to the FDIC for deposit insurance for PayPal Bank (FDIC) Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71 (IRS) Comment Letter to the Federal Reserve regarding Request for Information and Comments on the Future of the Federal Reserve Banks Check Services - Docket No. OP-1874 (Federal Reserve) Action Alerts - None Miscellaneous - Potential House field hearing on financial fraud (House) Approval of application for Kraken master account with the Federal Reserve (House)","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":54,"name":"Federal Deposit Insurance Corporation (FDIC)"},{"id":62,"name":"Federal Reserve System"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"SMB","general_issue_code_display":"Small Business","description":"CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks SBA Direct Lending Community banks and the SBA have a long, beneficial and cooperative private sector/public sector relationship and the SBA has historically not competed with banks in lending to businesses. Community banks are far superior in prudently underwriting and administering commercial lending relationships. The SBA originating and disbursing 7(a) loans will result in credit underwriting lapses which will put billions of taxpayer dollars at risk of loss. CBAI urges policymakers to prohibit the SBA from making direct 7(a) loans or otherwise expanding the institutions beyond well-regulated banks that could originate SBA loans. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Small Business Data Collection A Final Rule was published in March of 2023. The Final Rule was flawed because it exempted too few financial institutions and set the revenue threshold so high that it now encompasses too many businesses, in addition to raising privacy and other concerns. There have been legal challenges to the Final Rule. CBAI supports the reasonable implementation of this reporting requirement and opposed efforts by Farm Credit to exempt its lenders. Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Reporting Beneficial Ownership Information CBAI supports shifting the burden of collecting the BOI of community bank accountholders to the Financial Crimes Enforcement Network (FinCEN). The current requirement is flawed because it does not relieve community banks from this burden. There have been legal challenges to the reporting requirements. CBAI supports making FinCEN the sole repository of BOI and relieving community banks from this burden. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Harmful Climate Risk Regulations Community bankers high-contact and relationship-based lending model ensures that controls are in place to monitor climate risks on an ongoing basis. CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Consumer Financial Protection Bureau (CFPB) Reform and Exemptions for Community Banks CFPBs regulations must provide community banks with the flexibility to meet the needs of their customers - not a one-size-fits-all approach. They must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. In reforming the CFPB, the single director governance should be replaced by a five-member board or commission. A broader definition of firms that grant credit should be subject to the CFPB rules, and they should be robustly supervised and examined. The focus of any enhanced regulation of financial products should be on the largest banks and financial firms, the unregulated shadow financial industry, and fintechs - not community banks. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Action Alerts - None Letters - Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71 (IRS) Comment Letter to the Federal Reserve regarding Request for Information and Comments on the Future of the Federal Reserve Banks Check Services - Docket No. OP-1874 (Federal Reserve) Miscellaneous - Potential House field hearing on financial fraud (House)","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":62,"name":"Federal Reserve System"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"TAX","general_issue_code_display":"Taxation/Internal Revenue Code","description":"CBAI Federal Policy Priorities - Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Letters - Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71(IRS) Action Alerts - None Miscellaneous - None","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"ECN","general_issue_code_display":"Economics/Economic Development","description":"CBAI Federal Policy Priorities - Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 6644 the Housing for the 21st Century Act (Title VI) regarding the inclusion of FDIC modernizing insurance and reciprocal deposit rules, targeted regulatory and examination relief, lowering compliance costs, encouraging the formation of new community banks, and strengthen Minority Depository Institutions (MDIs) (House and Senate) S. 2651 or the ROAD Act which is the 21st Century ROAD to Housing Act regarding the inclusion of the provisions in H.R. 6644 (Housing for the 21st Century Act (Title VI) (House and Senate) H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Letters - Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71 (IRS) Comment Letter to the Federal Reserve regarding Request for Information and Comments on the Future of the Federal Reserve Banks Check Services - Docket No. OP-1874 (Federal Reserve) Action Alerts - Action Alert - Urge Your Representative to Support Community Bank Regulatory Relief (House) (See H.R. 6644 Housing for the 21st Century Act above) Miscellaneous - None","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":62,"name":"Federal Reserve System"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":1,"name":"SENATE"}]}],"conviction_disclosures":[],"foreign_entities":[],"affiliated_organizations":[]},{"url":"https://lda.gov/api/v1/filings/8c041376-c992-457a-94a7-eb83e0dd4f41/","filing_uuid":"8c041376-c992-457a-94a7-eb83e0dd4f41","filing_type":"Q1","filing_type_display":"1st Quarter - Report","filing_year":2026,"filing_period":"first_quarter","filing_period_display":"1st Quarter (Jan 1 - Mar 31)","filing_document_url":"https://lda.gov/filings/public/filing/8c041376-c992-457a-94a7-eb83e0dd4f41/print/","filing_document_content_type":"text/html","income":null,"expenses":"65000.00","expenses_method":"A","expenses_method_display":"A","posted_by_name":"David G Schroeder","dt_posted":"2026-04-10T15:38:54-04:00","termination_date":null,"registrant_country":"United States of America","registrant_ppb_country":null,"registrant_address_1":"901 Community Drive","registrant_address_2":null,"registrant_different_address":false,"registrant_city":"Springfield","registrant_state":"IL","registrant_zip":"62703","registrant":{"id":400531588,"url":"https://lda.gov/api/v1/registrants/400531588/","house_registrant_id":null,"name":"COMMUNITY BANKERS ASSOCIATION OF ILLINOIS","description":"Trade association representing Illinois' community banks and thrifts","address_1":"901 Community Drive","address_2":null,"address_3":null,"address_4":null,"city":"Springfield","state":"IL","state_display":"Illinois","zip":"62703","country":"US","country_display":"United States of America","ppb_country":"US","ppb_country_display":"United States of America","contact_name":"DAVID G. SCHROEDER","contact_telephone":"+1 847-909-8341","dt_updated":"2026-07-28T17:21:17.493355-04:00"},"client":{"id":192301,"url":"https://lda.gov/api/v1/clients/192301/","client_id":12,"name":"COMMUNITY BANKERS ASSOCIATION OF ILLINOIS","general_description":null,"client_government_entity":false,"client_self_select":true,"state":"IL","state_display":"Illinois","country":"US","country_display":"United States of America","ppb_state":"IL","ppb_state_display":"Illinois","ppb_country":"US","ppb_country_display":"United States of America","effective_date":"2010-01-01"},"lobbying_activities":[{"general_issue_code":"BAN","general_issue_code_display":"Banking","description":"CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. Legitimate Bank Service Charges and Fees are Not Hidden, Exploitive and Junk Fees and Necessary Consumer Financial Responsibility There have been misguided characterizations that community bank service charges and fees are exploitive, unfair and even unlawful. What some have disparaging called Junk fees are bank fees and service charges that are justified, disclosed, and accepted by the consumers who utilize bank products and services. CBAI does not support practices that abuse consumers, but policymakers must accept the position that it is the consumers responsibility to maintain a positive deposit account balance and make their debt payments in a timely manner. It is wrong for policymakers to excuse irresponsible consumer financial behavior and doing so may encourage unacceptable behavior. Realistic Perspective on Financial Inclusion CBAI strongly supports financial inclusion and believes every responsible and able consumer and business should have a banking relationship with their local community bank. There is indisputable proof that the banking industry excels at serving the banking needs of American households. CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the role of federal, state or governments to provide banking services. Governments can assist the private sector in financial inclusion through incentives to promote community banks offering basic accounts and small-dollar consumer loans, especially to low- and middle-income consumers, which are those most likely to be unbanked or underbanked. Protecting Consumers by Restricting the Sale of Mortgage Trigger Leads Trigger leads are generated by credit reporting agencies that contact information about consumers applying for residential mortgage loans to mortgage marketers. This practice is permitted but restricted. Our members report that many of these marketing communications fall short of the legal requirements. Trigger leads compromise consumer privacy, create a flood of unwanted (even harassing) solicitations, create confusion and result in complaints. CBAI supports legislation that would restrict credit reporting agencies from selling consumer contact information unless the applicant has opted in to receive these solicitations. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks SBA Direct Lending Community banks and the SBA have a long, beneficial and cooperative private sector/public sector relationship and the SBA has historically not competed with banks in lending to businesses. Community banks are far superior in prudently underwriting and administering commercial lending relationships. The SBA originating and disbursing 7(a) loans will result in credit underwriting lapses which will put billions of taxpayer dollars at risk of loss. CBAI urges policymakers to prohibit the SBA from making direct 7(a) loans or otherwise expanding the institutions beyond well-regulated banks that could originate SBA loans. Postal Banking CBAI believes postal banking is misguided and views any entry by the USPS into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the USPS to develop and offer banking services. Public Banking CBAI believes public banking is misguided and views any entry by federal, state or local governments into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the government to offer banking services. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Small Business Data Collection A Final Rule was published in March of 2023. The Final Rule was flawed because it exempted too few financial institutions and set the revenue threshold so high that it now encompasses too many businesses, in addition to raising privacy and other concerns. There have been legal challenges to the Final Rule. CBAI supports the reasonable implementation of this reporting requirement and opposed efforts by Farm Credit to exempt its lenders. Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Reporting Beneficial Ownership Information CBAI supports shifting the burden of collecting the BOI of community bank accountholders to the Financial Crimes Enforcement Network (FinCEN). The current requirement is flawed because it does not relieve community banks from this burden. There have been legal challenges to the reporting requirements. CBAI supports making FinCEN the sole repository of BOI and relieving community banks from this burden. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Closing the Industrial Loan Company (ILC) Regulatory Loophole CBAI has consistently supported the long-standing American policy of prohibiting the mixing of banking and commerce, which ILCs represent, because of the risks they pose to the financial system, the FDICs DIF, our economy, consumers and American taxpayers. The risk posed by ILCs, particularly large technology and ecommerce giants, is a regulatory loophole that allows their holding companies to escape from consolidated federal supervision and regulation. This loophole must be closed. Appropriate Regulation of Fintechs and Innovations in Financial Services The pace of innovation in financial services has been accelerating. Many of these new services are offered by financial technology companies - better known as fintechs. Financial innovation presents community banks with challenges and opportunities. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose unreasonable requirements on them, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. Prescriptive and Intrusive FDIC Corporate Governance Guidelines In 2023, the FDIC proposed new corporate governance and risk management guidelines. Although the guidelines only apply to covered institutions with $10 billion or more in assets, these overly prescriptive guidelines apply the same set of standards to larger community banks as they do to the nations largest banks. These guidelines would make it even more difficult to attract new directors, particularly those in rural areas. Harmful Climate Risk Regulations Community bankers high-contact and relationship-based lending model ensures that controls are in place to monitor climate risks on an ongoing basis. CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Consumer Financial Protection Bureau (CFPB) Reform and Exemptions for Community Banks CFPBs regulations must provide community banks with the flexibility to meet the needs of their customers - not a one-size-fits-all approach. They must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. In reforming the CFPB, the single director governance should be replaced by a five-member board or commission. A broader definition of firms that grant credit should be subject to the CFPB rules, and they should be robustly supervised and examined. The focus of any enhanced regulation of financial products should be on the largest banks and financial firms, the unregulated shadow financial industry, and fintechs - not community banks. De Novo Community Bank Formation, the Dual Banking System, and Charter Choice The chartering of many newly chartered (de novo) community banks is vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of continued banking industry consolidation. Hand in hand with renewed de novo bank formation is the importance of maintaining the dual banking system, where chartering and supervision are divided between the federal government and the states, and where the federal government supervision and regulation is divided between the Federal Reserve, Office of Comptroller of the Currency, and the Federal Deposit Insurance Corporation. Community banks should be able to choose the banking charter and associated prudential regulator that best fits their unique needs and business model. Sound Principles for Housing Government Sponsored Entity (GSE) Reform Reforms in government support for housing finance remain important to the future of the housing market and the U.S. economy. Unlike other private aggregators or investors, the GSEs have a mandate to serve all markets at all times, which is critical to maintaining liquidity particularly when markets are experiencing financial stress and private capital moves to the sidelines. Exiting receivership includes building capital to successfully operate within a broader housing finance framework, and bipartisan agreement on the proper role of the housing GSEs and the programs necessary to fulfill reasonable and consistent housing goals. Responsible Bank Merger Activity Some community banks have found it helpful to merge with other community banks to be able to spread the significant and escalating costs of regulatory compliance, cybersecurity, technology and innovation to remain highly competitive. Restrictive bank merger legislation or regulations should not apply to community banks. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Insure) Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts Too-Big-To-Not-Insure The 2023 failures of Silicon Valley Bank and Signature Bank revealed that policymakers have created a new category of very large banks - Too-Big-To-Not-Insure (although they will fail) because the FDIC decided to insure 100% of the uninsured deposits of these two failed banks. There must be accountability by both the banks and the regulators for their respective failures. In the future, if systemically important financial institutions (SIFIs) cause losses to the DIF then SIFIs should be responsible for reimbursing the DIF for all the losses they created. Too-Big-To-Fail The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 1799 the Threshold Modernization Act (All Sections) regarding thresholds for currency transaction reporting and Suspicious Activity Reporting (SAR) (House) H.R. 7056 the Community Bank Tailoring Act (All Sections) regarding indexing various asset-based and bank-regulatory reporting thresholds o nominal GDP for community banks (House) H.R. 6955 the Main Street Capital Access Act (All Sections) regarding regulatory fairness, transparency and right-sizing; promoting healthy, growing, and competitive banking industry; and improving access o funding and capital for small to mid-sized banks (House) H.R. 6644 the Housing for the 21st Century Act (Title VI) regarding he inclusion of FDIC modernizing insurance and reciprocal deposit rules, targeted regulatory and examination relief, lowering compliance costs, encouraging the formation of new community banks, and strengthen Minority Depository Institutions (MDIs) (House and Senate) S. 2651 or the ROAD Act which is the 21st Century ROAD to Housing Act regarding the inclusion of the provisions in H.R. 6644 (Housing for the 21st Century Act (Title VI) (House and Senate) H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Letters - Comment Letter to the FDIC regarding PayPal Holdings, Inc. application to the FDIC for deposit insurance for PayPal Bank (FDIC) Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71 (IRS) Comment Letter to the OCC, FDIC and Federal Reserve regarding Notice of Proposed Rulemaking: Regulatory Capital Rule: Revisions to the Community Bank Leverage Ratio Framework - Docket ID OCC-2025-0141, Federal Reserve Docket No. R-1876 and RIN 7100-AH08, and FDIC RIN 3064-AG17 (OCC, FDIC and Federal Reserve) Comment Letter to the Federal Reserve regarding Request for Information and Comment on Reserve Board Payment Account Prototype - Docket No. OP-1877 (aka Fed skinny payment accounts) (Federal Reserve) Comment Letter to the Federal Reserve regarding Request for Information and Comments on the Future of the Federal Reserve Banks Check Services - Docket No. OP-1874 (Federal Reserve) Comment Letter to the OCC regarding Notice of Proposed Rulemaking: Revised Guidelines - OCC Guidelines Establishing Heightened Standards for Certain Large Insured National Banks, Insured Federal Savings Associations, and Insured Federal Branches; Technical Amendments - Docket ID OCC-2025-0207 (OCC) Action Alerts - Action Alert - Urge Your Representative to Support Community Bank Regulatory Relief (House) (See H.R. 6644 Housing for the 21st Century Act above) Miscellaneous - Potential House field hearing on financial fraud (House) Approval of application for Kraken master account with the Federal Reserve (House) EGRPRA Outreach Meeting presentation on March 26, 2026, regarding de novos, particularly newly chartered community banks (OCC, FDIC, Federal Reserve)","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":54,"name":"Federal Deposit Insurance Corporation (FDIC)"},{"id":62,"name":"Federal Reserve System"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":183,"name":"Office of the Comptroller of the Currency (OCC)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"FIN","general_issue_code_display":"Financial Institutions/Investments/Securities","description":"CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. Legitimate Bank Service Charges and Fees are Not Hidden, Exploitive and Junk Fees and Necessary Consumer Financial Responsibility There have been misguided characterizations that community bank service charges and fees are exploitive, unfair and even unlawful. What some have disparaging called Junk fees are bank fees and service charges that are justified, disclosed, and accepted by the consumers who utilize bank products and services. CBAI does not support practices that abuse consumers, but policymakers must accept the position that it is the consumers responsibility to maintain a positive deposit account balance and make their debt payments in a timely manner. It is wrong for policymakers to excuse irresponsible consumer financial behavior and doing so may encourage unacceptable behavior. Realistic Perspective on Financial Inclusion CBAI strongly supports financial inclusion and believes every responsible and able consumer and business should have a banking relationship with their local community bank. There is indisputable proof that the banking industry excels at serving the banking needs of American households. CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the role of federal, state or governments to provide banking services. Governments can assist the private sector in financial inclusion through incentives to promote community banks offering basic accounts and small-dollar consumer loans, especially to low- and middle-income consumers, which are those most likely to be unbanked or underbanked. Protecting Consumers by Restricting the Sale of Mortgage Trigger Leads Trigger leads are generated by credit reporting agencies that contact information about consumers applying for residential mortgage loans to mortgage marketers. This practice is permitted but restricted. Our members report that many of these marketing communications fall short of the legal requirements. Trigger leads compromise consumer privacy, create a flood of unwanted (even harassing) solicitations, create confusion and result in complaints. CBAI supports legislation that would restrict credit reporting agencies from selling consumer contact information unless the applicant has opted in to receive these solicitations. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks SBA Direct Lending Community banks and the SBA have a long, beneficial and cooperative private sector/public sector relationship and the SBA has historically not competed with banks in lending to businesses. Community banks are far superior in prudently underwriting and administering commercial lending relationships. The SBA originating and disbursing 7(a) loans will result in credit underwriting lapses which will put billions of taxpayer dollars at risk of loss. CBAI urges policymakers to prohibit the SBA from making direct 7(a) loans or otherwise expanding the institutions beyond well-regulated banks that could originate SBA loans. Postal Banking CBAI believes postal banking is misguided and views any entry by the USPS into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the USPS to develop and offer banking services. Public Banking CBAI believes public banking is misguided and views any entry by federal, state or local governments into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the government to offer banking services. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Small Business Data Collection A Final Rule was published in March of 2023. The Final Rule was flawed because it exempted too few financial institutions and set the revenue threshold so high that it now encompasses too many businesses, in addition to raising privacy and other concerns. There have been legal challenges to the Final Rule. CBAI supports the reasonable implementation of this reporting requirement and opposed efforts by Farm Credit to exempt its lenders. Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Reporting Beneficial Ownership Information CBAI supports shifting the burden of collecting the BOI of community bank accountholders to the Financial Crimes Enforcement Network (FinCEN). The current requirement is flawed because it does not relieve community banks from this burden. There have been legal challenges to the reporting requirements. CBAI supports making FinCEN the sole repository of BOI and relieving community banks from this burden. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Closing the Industrial Loan Company (ILC) Regulatory Loophole CBAI has consistently supported the long-standing American policy of prohibiting the mixing of banking and commerce, which ILCs represent, because of the risks they pose to the financial system, the FDICs DIF, our economy, consumers and American taxpayers. The risk posed by ILCs, particularly large technology and ecommerce giants, is a regulatory loophole that allows their holding companies to escape from consolidated federal supervision and regulation. This loophole must be closed. Appropriate Regulation of Fintechs and Innovations in Financial Services The pace of innovation in financial services has been accelerating. Many of these new services are offered by financial technology companies - better known as fintechs. Financial innovation presents community banks with challenges and opportunities. Policymakers should reasonably assist community banks to prepare for this new and evolving era, not pose unreasonable requirements on them, and not give fintechs any competitive advantages over community banks by subjecting them to lesser regulatory requirements. Prescriptive and Intrusive FDIC Corporate Governance Guidelines In 2023, the FDIC proposed new corporate governance and risk management guidelines. Although the guidelines only apply to covered institutions with $10 billion or more in assets, these overly prescriptive guidelines apply the same set of standards to larger community banks as they do to the nations largest banks. These guidelines would make it even more difficult to attract new directors, particularly those in rural areas. Harmful Climate Risk Regulations Community bankers high-contact and relationship-based lending model ensures that controls are in place to monitor climate risks on an ongoing basis. CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Consumer Financial Protection Bureau (CFPB) Reform and Exemptions for Community Banks CFPBs regulations must provide community banks with the flexibility to meet the needs of their customers - not a one-size-fits-all approach. They must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. In reforming the CFPB, the single director governance should be replaced by a five-member board or commission. A broader definition of firms that grant credit should be subject to the CFPB rules, and they should be robustly supervised and examined. The focus of any enhanced regulation of financial products should be on the largest banks and financial firms, the unregulated shadow financial industry, and fintechs - not community banks. De Novo Community Bank Formation, the Dual Banking System, and Charter Choice The chartering of many newly chartered (de novo) community banks is vitally important to maintaining a strong, growing, evolving and vibrant profession in the face of continued banking industry consolidation. Hand in hand with renewed de novo bank formation is the importance of maintaining the dual banking system, where chartering and supervision are divided between the federal government and the states, and where the federal government supervision and regulation is divided between the Federal Reserve, Office of Comptroller of the Currency, and the Federal Deposit Insurance Corporation. Community banks should be able to choose the banking charter and associated prudential regulator that best fits their unique needs and business model. Sound Principles for Housing Government Sponsored Entity (GSE) Reform Reforms in government support for housing finance remain important to the future of the housing market and the U.S. economy. Unlike other private aggregators or investors, the GSEs have a mandate to serve all markets at all times, which is critical to maintaining liquidity particularly when markets are experiencing financial stress and private capital moves to the sidelines. Exiting receivership includes building capital to successfully operate within a broader housing finance framework, and bipartisan agreement on the proper role of the housing GSEs and the programs necessary to fulfill reasonable and consistent housing goals. Responsible Bank Merger Activity Some community banks have found it helpful to merge with other community banks to be able to spread the significant and escalating costs of regulatory compliance, cybersecurity, technology and innovation to remain highly competitive. Restrictive bank merger legislation or regulations should not apply to community banks. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail (and now Too-Big-To-Not-Insure) Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts Too-Big-To-Not-Insure The 2023 failures of Silicon Valley Bank and Signature Bank revealed that policymakers have created a new category of very large banks - Too-Big-To-Not-Insure (although they will fail) because the FDIC decided to insure 100% of the uninsured deposits of these two failed banks. There must be accountability by both the banks and the regulators for their respective failures. In the future, if systemically important financial institutions (SIFIs) cause losses to the DIF then SIFIs should be responsible for reimbursing the DIF for all the losses they created. Too-Big-To-Fail The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 1799 the Threshold Modernization Act (All Sections) regarding thresholds for currency transaction reporting and Suspicious Activity Reporting (SAR) (House) H.R. 7056 the Community Bank Tailoring Act (All Sections) regarding indexing various asset-based and bank-regulatory reporting thresholds o nominal GDP for community banks (House) H.R. 6955 the Main Street Capital Access Act (All Sections) regarding regulatory fairness, transparency and right-sizing; promoting healthy, growing, and competitive banking industry; and improving access o funding and capital for small to mid-sized banks (House) H.R. 6644 the Housing for the 21st Century Act (Title VI) regarding he inclusion of FDIC modernizing insurance and reciprocal deposit rules, targeted regulatory and examination relief, lowering compliance costs, encouraging the formation of new community banks, and strengthen Minority Depository Institutions (MDIs) (House and Senate) S. 2651 or the ROAD Act which is the 21st Century ROAD to Housing Act regarding the inclusion of the provisions in H.R. 6644 (Housing for the 21st Century Act (Title VI) (House and Senate) H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Letters - Comment Letter to the FDIC regarding PayPal Holdings, Inc. application to the FDIC for deposit insurance for PayPal Bank (FDIC) Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71 (IRS) Comment Letter to the OCC, FDIC and Federal Reserve regarding Notice of Proposed Rulemaking: Regulatory Capital Rule: Revisions to the Community Bank Leverage Ratio Framework - Docket ID OCC-2025-0141, Federal Reserve Docket No. R-1876 and RIN 7100-AH08, and FDIC RIN 3064-AG17 (OCC, FDIC and Federal Reserve) Comment Letter to the Federal Reserve regarding Request for Information and Comment on Reserve Board Payment Account Prototype - Docket No. OP-1877 (aka Fed skinny payment accounts) (Federal Reserve) Comment Letter to the Federal Reserve regarding Request for Information and Comments on the Future of the Federal Reserve Banks Check Services - Docket No. OP-1874 (Federal Reserve) Comment Letter to the OCC regarding Notice of Proposed Rulemaking: Revised Guidelines - OCC Guidelines Establishing Heightened Standards for Certain Large Insured National Banks, Insured Federal Savings Associations, and Insured Federal Branches; Technical Amendments - Docket ID OCC-2025-0207 (OCC) Action Alerts - Action Alert - Urge Your Representative to Support Community Bank Regulatory Relief (House) (See H.R. 6644 Housing for the 21st Century Act above) Miscellaneous - Potential House field hearing on financial fraud (House) Approval of application for Kraken master account with the Federal Reserve (House) EGRPRA Outreach Meeting presentation on March 26, 2026, regarding de novos, particularly newly chartered community banks (OCC, FDIC, Federal Reserve)","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":54,"name":"Federal Deposit Insurance Corporation (FDIC)"},{"id":62,"name":"Federal Reserve System"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":183,"name":"Office of the Comptroller of the Currency (OCC)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"AGR","general_issue_code_display":"Agriculture","description":"CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Small Business Data Collection A Final Rule was published in March of 2023. The Final Rule was flawed because it exempted too few financial institutions and set the revenue threshold so high that it now encompasses too many businesses, in addition to raising privacy and other concerns. There have been legal challenges to the Final Rule. CBAI supports the reasonable implementation of this reporting requirement and opposed efforts by Farm Credit to exempt its lenders. Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Reporting Beneficial Ownership Information CBAI supports shifting the burden of collecting the BOI of community bank accountholders to the Financial Crimes Enforcement Network (FinCEN). The current requirement is flawed because it does not relieve community banks from this burden. There have been legal challenges to the reporting requirements. CBAI supports making FinCEN the sole repository of BOI and relieving community banks from this burden. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Harmful Climate Risk Regulations Community bankers high-contact and relationship-based lending model ensures that controls are in place to monitor climate risks on an ongoing basis. CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Sound Principles for Housing Government Sponsored Entity (GSE) Reform Reforms in government support for housing finance remain important to the future of the housing market and the U.S. economy. Unlike other private aggregators or investors, the GSEs have a mandate to serve all markets at all times, which is critical to maintaining liquidity particularly when markets are experiencing financial stress and private capital moves to the sidelines. Exiting receivership includes building capital to successfully operate within a broader housing finance framework, and bipartisan agreement on the proper role of the housing GSEs and the programs necessary to fulfill reasonable and consistent housing goals. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 6644 the Housing for the 21st Century Act (Title VI) regarding he inclusion of FDIC modernizing insurance and reciprocal deposit rules, targeted regulatory and examination relief, lowering compliance costs, encouraging the formation of new community banks, and strengthen Minority Depository Institutions (MDIs) (House) S. 2651 or the ROAD Act which is the 21st Century ROAD to Housing Act regarding the inclusion of the provisions in H.R. 6644 (Housing for the 21st Century Act (Title VI) (House and Senate) H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Letters - Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71 (IRS) Comment Letter to the Federal Reserve regarding Request for Information and Comments on the Future of the Federal Reserve Banks Check Services - Docket No. OP-1874 (Federal Reserve) Action Alerts - None Miscellaneous - Potential House field hearing on financial fraud (House)","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":62,"name":"Federal Reserve System"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"CSP","general_issue_code_display":"Consumer Issues/Safety/Products","description":"CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Legitimate Bank Service Charges and Fees are Not Hidden, Exploitive and Junk Fees and Necessary Consumer Financial Responsibility There have been misguided characterizations that community bank service charges and fees are exploitive, unfair and even unlawful. What some have disparaging called Junk fees are bank fees and service charges that are justified, disclosed, and accepted by the consumers who utilize bank products and services. CBAI does not support practices that abuse consumers, but policymakers must accept the position that it is the consumers responsibility to maintain a positive deposit account balance and make their debt payments in a timely manner. It is wrong for policymakers to excuse irresponsible consumer financial behavior and doing so may encourage unacceptable behavior. Realistic Perspective on Financial Inclusion CBAI strongly supports financial inclusion and believes every responsible and able consumer and business should have a banking relationship with their local community bank. There is indisputable proof that the banking industry excels at serving the banking needs of American households. CBAI supports government initiatives that educate consumers and encourage financial inclusion, but it is not the role of federal, state or governments to provide banking services. Governments can assist the private sector in financial inclusion through incentives to promote community banks offering basic accounts and small-dollar consumer loans, especially to low- and middle-income consumers, which are those most likely to be unbanked or underbanked. Protecting Consumers by Restricting the Sale of Mortgage Trigger Leads Trigger leads are generated by credit reporting agencies that contact information about consumers applying for residential mortgage loans to mortgage marketers. This practice is permitted but restricted. Our members report that many of these marketing communications fall short of the legal requirements. Trigger leads compromise consumer privacy, create a flood of unwanted (even harassing) solicitations, create confusion and result in complaints. CBAI supports legislation that would restrict credit reporting agencies from selling consumer contact information unless the applicant has opted in to receive these solicitations. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks Postal Banking CBAI believes postal banking is misguided and views any entry by the USPS into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the USPS to develop and offer banking services. Public Banking CBAI believes public banking is misguided and views any entry by federal, state or local governments into banking services as a significant and government-sponsored competitive threat to private-sector and tax-paying community banks. By better utilizing the vast network of community banks, which are already fully staffed by experienced and dedicated banking professionals, there is no need for the government to offer banking services. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Closing the Industrial Loan Company (ILC) Regulatory Loophole CBAI has consistently supported the long-standing American policy of prohibiting the mixing of banking and commerce, which ILCs represent, because of the risks they pose to the financial system, the FDICs DIF, our economy, consumers and American taxpayers. The risk posed by ILCs, particularly large technology and ecommerce giants, is a regulatory loophole that allows their holding companies to escape from consolidated federal supervision and regulation. This loophole must be closed. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Consumer Financial Protection Bureau (CFPB) Reform and Exemptions for Community Banks CFPBs regulations must provide community banks with the flexibility to meet the needs of their customers - not a one-size-fits-all approach. They must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. In reforming the CFPB, the single director governance should be replaced by a five-member board or commission. A broader definition of firms that grant credit should be subject to the CFPB rules, and they should be robustly supervised and examined. The focus of any enhanced regulation of financial products should be on the largest banks and financial firms, the unregulated shadow financial industry, and fintechs - not community banks. Sound Principles for Housing Government Sponsored Entity (GSE) Reform Reforms in government support for housing finance remain important to the future of the housing market and the U.S. economy. Unlike other private aggregators or investors, the GSEs have a mandate to serve all markets at all times, which is critical to maintaining liquidity particularly when markets are experiencing financial stress and private capital moves to the sidelines. Exiting receivership includes building capital to successfully operate within a broader housing finance framework, and bipartisan agreement on the proper role of the housing GSEs and the programs necessary to fulfill reasonable and consistent housing goals. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Letters - Comment Letter to the FDIC regarding PayPal Holdings, Inc. application to the FDIC for deposit insurance for PayPal Bank (FDIC) Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71 (IRS) Comment Letter to the Federal Reserve regarding Request for Information and Comments on the Future of the Federal Reserve Banks Check Services - Docket No. OP-1874 (Federal Reserve) Action Alerts - None Miscellaneous - Potential House field hearing on financial fraud (House) Approval of application for Kraken master account with the Federal Reserve (House)","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":54,"name":"Federal Deposit Insurance Corporation (FDIC)"},{"id":62,"name":"Federal Reserve System"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"SMB","general_issue_code_display":"Small Business","description":"CBAI Federal Policy Priorities - Bank Regulators Fulfilling Their Responsibilities Regarding Check Fraud Including Reimbursement for Fraudulently Altered Returned Checks Community banks continue to experience a growing problem of check fraud including reimbursements for fraudulently altered checks drawn on their customers accounts. The problem in the banking industry has been identified by our members as being enabled by the nations largest banks and credit unions, where fraudulent accounts are opened and fraudulent checks are deposited, which clear back to many community banks, harming them and their customers, in addition to undermining the publics confidence in the nations banking and financial system. CBAI urges the regulators to fulfill their responsibilities to address this problem by initiating Joint Supervisory Guidance and ramping up their examination and enforcement against the largest financial institutions to ensure they are held accountable for their apparent safety and soundness and compliance inadequacies. Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. Governments Unnecessary Intrusion into Banking and Lending Which Displaces Community Banks SBA Direct Lending Community banks and the SBA have a long, beneficial and cooperative private sector/public sector relationship and the SBA has historically not competed with banks in lending to businesses. Community banks are far superior in prudently underwriting and administering commercial lending relationships. The SBA originating and disbursing 7(a) loans will result in credit underwriting lapses which will put billions of taxpayer dollars at risk of loss. CBAI urges policymakers to prohibit the SBA from making direct 7(a) loans or otherwise expanding the institutions beyond well-regulated banks that could originate SBA loans. New Credit Card Routing Mandates Efforts to mandate credit card routing is ill conceived policymaking that will fail to benefit consumers by forcing a costly overhaul of the credit card payments landscape. The beneficiaries of the new mandates will be the largest merchants (not small businesses) which will not pass their savings on to consumers. CBAI supports greater competition and opposes concentrations in financial services represented by the too-big-to-fail banks and oligopolies like VISA and MasterCard, but misguided legislation is not the solution to the problems they create. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Small Business Data Collection A Final Rule was published in March of 2023. The Final Rule was flawed because it exempted too few financial institutions and set the revenue threshold so high that it now encompasses too many businesses, in addition to raising privacy and other concerns. There have been legal challenges to the Final Rule. CBAI supports the reasonable implementation of this reporting requirement and opposed efforts by Farm Credit to exempt its lenders. Customer Data Sharing A Final Rule was published in October of 2024. The Final Rule was flawed because it exempted too few financial institutions, ignores the costs of providing this service to consumers and does not adequately protect consumers and their community banks or compensate them from any losses related to data misuse, breaches and fraud. Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Reporting Beneficial Ownership Information CBAI supports shifting the burden of collecting the BOI of community bank accountholders to the Financial Crimes Enforcement Network (FinCEN). The current requirement is flawed because it does not relieve community banks from this burden. There have been legal challenges to the reporting requirements. CBAI supports making FinCEN the sole repository of BOI and relieving community banks from this burden. Federal Safe Harbor for Banking Cannabis-Related Businesses Without taking a position on the legalization of cannabis, CBAI supports a federal safe harbor from sanctions for financial institutions that choose to serve legally compliant cannabis-related businesses (CRBs) and ancillary businesses that have commercial relationships with CBRs, in states where cannabis is legal. Allowing these businesses access to the traditional banking system and its services, versus operating exclusively in cash, is a public safety issue. Harmful Climate Risk Regulations Community bankers high-contact and relationship-based lending model ensures that controls are in place to monitor climate risks on an ongoing basis. CBAI opposes any climate change regulations that will adversely impact community banks and their ability to support their customers and communities. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Enhanced Data, Cyber and Payment Card Security (Data Security) The need for data security is paramount in financial services. Community banks are strong guardians of the security and confidentiality of their customers information. Enhanced security standards should be enforced through a tiered system where the more restrictive rules are imposed on the largest members of the financial system and economy (bot community banks) where their lapses pose the greatest threat to the largest number of consumers. Consumer Financial Protection Bureau (CFPB) Reform and Exemptions for Community Banks CFPBs regulations must provide community banks with the flexibility to meet the needs of their customers - not a one-size-fits-all approach. They must not be burdened with additional and unnecessary regulatory requirements that would prevent them from serving their customers and communities. In reforming the CFPB, the single director governance should be replaced by a five-member board or commission. A broader definition of firms that grant credit should be subject to the CFPB rules, and they should be robustly supervised and examined. The focus of any enhanced regulation of financial products should be on the largest banks and financial firms, the unregulated shadow financial industry, and fintechs - not community banks. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Action Alerts - None Letters - Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71 (IRS) Comment Letter to the Federal Reserve regarding Request for Information and Comments on the Future of the Federal Reserve Banks Check Services - Docket No. OP-1874 (Federal Reserve) Miscellaneous - Potential House field hearing on financial fraud (House)","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":62,"name":"Federal Reserve System"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"TAX","general_issue_code_display":"Taxation/Internal Revenue Code","description":"CBAI Federal Policy Priorities - Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. Responsible Regulation of Digital Assets - Cryptocurrency, Central Bank Digital Currency (CBDC), Stablecoins and Decentralized Finance (DeFi) The risks posed by digital assets (cryptocurrency), central Bank digital currency (CBDC) and stablecoin, and decentralized finance (DeFi) are enormous, as well as the consequences for monetary policy, our financial system, and the banking industry. They pose threats to the privacy and security of consumers and small businesses. There is no single regulator responsible for this rapidly growing sector which combines elements of currency, payments and investments, and there is insufficient transparency and lack of accountability in this ecosystem. Policymakers must develop and implement a consistent federal regulatory framework that does not permit digital assets and DeFi to offer financial services or products without being subject to the same regulations as community banks and deny nonbank stablecoin issuers access to the Federal Reserve master account, both of which would threaten the essential and highly successful business model of responsible community banks. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Letters - Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71(IRS) Action Alerts - None Miscellaneous - None","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"ECN","general_issue_code_display":"Economics/Economic Development","description":"CBAI Federal Policy Priorities - Agriculture and Rural America In the 119th Congress, CBAI strongly advocates for the passage of a multi-year Farm Bill that provides ample funding for commodity programs and rural broadband, maintains strong crop insurance products, approves higher USDA-guaranteed loan limits and expedited USDA Express program approvals, and prevents the expansion of the Farm Credit System into non-farm lending activities and opposes their exemption from the Section 1071 small business data reporting requirements. Community banks and their agricultural borrowers merit favorable tax treatment for interest income on ag loans secured by ag property and primary residences in ag communities. This will help sustain and strengthen ag lending by community banks and reduce interest expenses for their banks ag borrowers. The Federal Home Loan Banks (FHLBs) in Their Comprehensive Review by the FHFA The FHLB System is an admirable public-private partnership where the FHLBs banks provide short-term liquidity, long-term funding, mortgage-related products, and other financial services to help their owner-members weather crisis and provide affordable credit to support the local communities. FHLBanks contributes a substantial portion of its income to affordable housing and community development in their respective districts. The Federal Housing Finance Agency (FHFA) has embarked on a comprehensive review of the FHLBs. CBAI recommends that the FHFA should not seek to disrupt the cooperative structure, regional nature, special functions, and the unique purposes of the FHLBanks. Reasonable Regulatory Rules and Implementation Modernizing the Community Reinvestment Act The Final Joint Rule was published in October of 2023. The Final Joint Rule was flawed because it exempted too few financial institutions and for many other reasons. There have been legal challenges to the Final Joint Rule. CBAI supports the reasonable implementation of the CRA that includes credit unions being subject to the CRA. Meaningful Regulatory Relief for Community Banks and Regulatory Overreach CBAI joins the ICBA in supporting a more efficient system of rules and regulations, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to support the nations economic growth and development in all parts of the country. Many new and significant rules have been approved which individually and collectively present incredible challenges for community banks which are less likely to be able to comply with these many new requirements. CBAI urges carefully constructed legislation and regulation, robust congressional oversight of the regulators, and a moratorium on new rules until the impact of existing rules can be thoroughly assessed to minimize the damages to community banks. Credit Unions and Their Expanded Powers Credit unions have long since strayed from their founding purposes, weaponizing their competitive advantages, and are virtually indistinguishable from tax-paying community banks. Credit union acquisitions of community banks are increasing at an alarming pace and is an abuse of the tax code which exacerbates consolidation among financial institutions, negatively impacts all taxpayers, and reduces consumer choice. Credit union abuse of their tax exemption is an existential threat to community banks and the communities they serve and must end. Farm Credit System and its Expanded Powers The Farm Credit System (FCS) has long since strayed from its founding purpose, weaponizing its competitive advantages against community banks. The FCS is the only government sponsored entity (GSE) that competes directly with community banks. Its lenders leverage their tax and funding advantages as a GSE to steal away many of the best agriculture loans from community banks, which is contrary to their mission of serving young and beginning farmers and ranchers. This blatant and continued discrimination against community banks must end, the FCS competitive advantages must be reined in, and the playing field must be leveled for community banks. The Federal Reserves Role in Payments System Improvement (FedNow Service) The FedNow Service is a significant payments system improvement. The payments system must not be monopolized by The Clearing House and its large bank owners with their RTP Network. Community banks, consumers and small businesses must rely on the Federal Reserve to provide access to a safe and secure payments system, which requires the Fed to play a preeminent role in system improvements. The FedNow Service should have robust capabilities, should be interoperable with other payments systems and should only be accessed by regulated financial institutions - not Amazon, Walmart, and the many fintechs that are seeking direct access to the payment rails. Finally Address the Risks of Too-Big-To-Fail Banks and Financial Firms, to Protect Community Banks, our Financial System, the Economy, and American Taxpayers from Future Bailouts The Great Financial Crisis, and the mini crisis caused by the failures of SVB and SBNY, were caused by the misconduct of the nations largest banks and financial firms and by banking regulators that did not ensure the safety and soundness of these financial behemoths. The megabanks and financial firms have proven, at great cost to American taxpayers, that they cannot be managed, supervised, disciplined or prosecuted. They are clearly too-big-to-change, too-big-to-fail, and must be downsized. This necessary policy objective can be accomplished by separating the traditional deposit-taking and lending activities of the largest banks from their speculative investment banking, securities underwriting, and market making activities. The time to act is now before the next financial crisis. (House and Senate) Legislation and Regulation - H.R. 6644 the Housing for the 21st Century Act (Title VI) regarding the inclusion of FDIC modernizing insurance and reciprocal deposit rules, targeted regulatory and examination relief, lowering compliance costs, encouraging the formation of new community banks, and strengthen Minority Depository Institutions (MDIs) (House and Senate) S. 2651 or the ROAD Act which is the 21st Century ROAD to Housing Act regarding the inclusion of the provisions in H.R. 6644 (Housing for the 21st Century Act (Title VI) (House and Senate) H.R. 7567 or the Farm, Food, and National Security Act of 2026 (aka the Farm Bill) regarding strengthening the farm safety net, USDA guaranteed loan improvements, Farm Credit System (FCS) expansion provisions, Essential Community Facility (ECF) lending expansion, FCS ownership of Rural Business Investment Corporations (RBICs), loans to businesses for aquatic-related purposes, and potential amendment - expanding FCS home mortgage lending to towns of 10,000 (House) Letters - Comment Letter to the IRS regarding interim guidance concerning interest on loans secured by rural or agricultural real property under section 139L of the Internal Revenue Code - Notice 2025-71 (IRS) Comment Letter to the Federal Reserve regarding Request for Information and Comments on the Future of the Federal Reserve Banks Check Services - Docket No. OP-1874 (Federal Reserve) Action Alerts - Action Alert - Urge Your Representative to Support Community Bank Regulatory Relief (House) (See H.R. 6644 Housing for the 21st Century Act above) Miscellaneous - None","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":52194,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":"GLENN","last_name":"SCHROEDER","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":62,"name":"Federal Reserve System"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":1,"name":"SENATE"}]}],"conviction_disclosures":[],"foreign_entities":[],"affiliated_organizations":[]},{"url":"https://lda.gov/api/v1/filings/e00c4483-52f0-44d5-abb7-5c8ace4762a2/","filing_uuid":"e00c4483-52f0-44d5-abb7-5c8ace4762a2","filing_type":"Q1","filing_type_display":"1st Quarter - Report","filing_year":2026,"filing_period":"first_quarter","filing_period_display":"1st Quarter (Jan 1 - Mar 31)","filing_document_url":"https://lda.gov/filings/public/filing/e00c4483-52f0-44d5-abb7-5c8ace4762a2/print/","filing_document_content_type":"text/html","income":null,"expenses":"310000.00","expenses_method":"A","expenses_method_display":"A","posted_by_name":"Kata Sybenga","dt_posted":"2026-04-13T11:28:56-04:00","termination_date":null,"registrant_country":"United States of America","registrant_ppb_country":null,"registrant_address_1":"800 K Street, NW","registrant_address_2":"Suite 1000","registrant_different_address":false,"registrant_city":"Washington","registrant_state":"DC","registrant_zip":"20001","registrant":{"id":28708,"url":"https://lda.gov/api/v1/registrants/28708/","house_registrant_id":31081,"name":"NATIONAL TREASURY EMPLOYEES UNION","description":null,"address_1":"800 K Street, NW","address_2":"Suite 1000","address_3":null,"address_4":null,"city":"Washington","state":"DC","state_display":"District of Columbia","zip":"20001","country":"US","country_display":"United States of America","ppb_country":"US","ppb_country_display":"United States of America","contact_name":"KATA SYBENGA","contact_telephone":"+1 202-572-5500","dt_updated":"2026-07-31T11:15:48.152132-04:00"},"client":{"id":134581,"url":"https://lda.gov/api/v1/clients/134581/","client_id":12,"name":"NATIONAL TREASURY EMPLOYEES UNION","general_description":null,"client_government_entity":false,"client_self_select":true,"state":"DC","state_display":"District of Columbia","country":"US","country_display":"United States of America","ppb_state":"DC","ppb_state_display":"District of Columbia","ppb_country":"US","ppb_country_display":"United States of America","effective_date":"2007-08-09"},"lobbying_activities":[{"general_issue_code":"BUD","general_issue_code_display":"Budget/Appropriations","description":"Draft Senate FY 2026 Homeland Security Appropriations bill Draft House FY 2027 Financial Services and General Government Appropriations bill H. Con. Res. 15, Calling an Article V Convention for proposing a Fiscal Responsibility Amendment to the United States Constitution and stipulating ratification by a vote of We the People, and for other purposes. H. J. Res. 110, Proposing a balanced budget amendment to the Constitution of the United States. H. J. Res. 112, Proposing an amendment to the Constitution of the United States related to the public debt. H. J. Res. 139, Proposing an amendment to the Constitution of the United States requiring a balanced budget for the Federal Government. H.R. 182, Default Prevention Act H.R. 191, Inflation Reduction Act of 2025 H.R. 196, Family and Small Business Taxpayer Protection Act H.R. 199, Implementing DOGE Act H.R. 222, Sustainable Budget Act of 2025 H.R. 374, DIRECT Act H.R. 654, TABS Act of 2025 H.R. 814, Defund the CFPB Act S. 303, Defund the CFPB Act H.R. 1180, To repeal the Impoundment Control Act of 1974. S. 515, A bill to repeal the Impoundment Control Act of 1974. H.R. 1916, Pay Our Border Patrol and Customs Agents Act of 2025 H.R. 2050, Homeland Heroes Pay Act H.R. 3001, To advance commonsense priorities. H.R. 3141, CFPB Budget Integrity Act H.R. 3289, Fiscal Commission Act H.R. 4016, Department of Defense Appropriations Act, 2026 S. 2572, Department of Defense Appropriations Act, 2026 H.R. 4178, Enforce the Caps Act H.R. 4213, Department of Homeland Security Appropriations Act, 2026 H.R. 4229, To amend the Impoundment Control Act of 1974 to require prior approval from Congress before the Comptroller General may pursue a civil action under such Act, and for other purposes. H.R. 4273, Over-the-Counter Monograph Drug User Fee Amendments H.R. 4553, Energy and Water Development and Related Agencies Appropriations Act, 2026 S. 3293, Energy and Water Development and Related Agencies Appropriations Act, 2026 H.R. 4754, Department of the Interior, Environment, and Related Agencies Appropriations Act, 2026 S. 2431, Department of the Interior, Environment, and Related Agencies Appropriations Act, 2026 H.R. 4765, Securing our Border Act H.R. 5130, Prevent Government Shutdowns Act of 2025 S. 2721, Prevent Government Shutdowns Act of 2025 H.R. 5166, Financial Services and General Government Appropriations Act, 2026 S. 3290, Financial Services and General Government Appropriations Act, 2026 H.R. 5220, Congressional Power of the Purse Act H.R. 5260, Pay Our Border Patrol and Customs Agents Act H.R. 5304, Departments of Labor, Health and Human Services, and Education, and Related Agencies Appropriations Act, 2026 S. 2587, Departments of Labor, Health and Human Services, and Education, and Related Agencies Appropriations Act, 2026 H.R. 5342, Commerce, Justice, Science, and Related Agencies Appropriations Act, 2026 S. 2354, Commerce, Justice, Science, and Related Agencies Appropriations Act, 2026 H.R. 5398, Pay Our Homeland Defenders Act of 2026 H.R. 5405, Government Shutdown Prevention Act of 2025 H.R. 5438, Incentivize Savings Act H.R. 5450, Continuing Appropriations and Extensions and Other Matters Act, 2026 S. 2882, Continuing Appropriations and Extensions and Other Matters Act, 2026 H.R. 5542, End Government Shutdowns Act H.R. 5552, Eliminate Shutdowns Act H.R. 5619, Federal Firefighter Paycheck Protection Act H.R. 5628, Pay Workers What Theyve Earned Act H.R. 5801, Shutdown Fairness Act S. 3012, Shutdown Fairness Act H.R. 5802, MAGA Act H.R. 5870, Prevent Government Shutdowns Act H.R. 5893, GUARD Act H.R. 5998, To provide for the continued operation of the Hatch Act Unit of the Office of Special Counsel during a lapse in appropriations, and for other purposes. H.R. 6938, Commerce, Justice, Science; Energy and Water Development; and Interior and Environment Appropriations Act, 2026 H.R. 7006, Financial Services and General Government and National Security, Department of State, and Related Programs Appropriations Act, 2026 H.R. 7137, Shutdown Fairness Act S. 3168, Shutdown Fairness Act H.R. 7147, Further Additional Continuing Appropriations Act, 2026 H.R. 7148, Consolidated Appropriations Act, 2026 H.R. 7295, Comprehensive Congressional Budget Act of 2026 H.R. 7322, True Shutdown Fairness Act H.R. 7481, Department of Homeland Security Appropriations Act, 2026 H.R. 7617, To provide funding for administrative expenses of the Department of Homeland Security during any lapse in appropriations during fiscal year 2026, to require that the Department be responsive to congressional offices during such a lapse in appropriations, and for other purposes. H.R. 7744, Department of Homeland Security Appropriations Act, 2026 H.R. 7844, To provide the Secretary of Homeland Security with the authority to transfer funds between accounts under the Department of Homeland Security during a lapse in appropriations, and for other purposes. H.R. 8029, Pay Our Homeland Defenders Act S. J. Res. 97, A joint resolution proposing a balanced budget amendment to the Constitution of the United States. S. Res. 654, A resolution expressing the sense of the Senate that the United States should reduce and maintain the Federal unified budget deficit at or below 3 percent of gross domestic product. S. 175, A bill to rescind unobligated balances appropriated for the IRS and use for an External Revenue Service S. 181, A bill to require agencies submit zero-based budgets. S. 360, To provide for across the board rescissions of non-security discretionary spending S. 481, Securing our Border Act S. 2806, Eliminate Shutdowns Act S. 3001, Shutdown Fairness Act S. 3039, True Shutdown Fairness Act S. 3165, True Shutdown Fairness Act S. 3043, Military and Federal Employee Protection Act S. 3066, Pay the People Act S. 3681, Keep Our Border Agents Paid Act S. 3951, Balanced Budget Responsibility Act of 2026 S. 4012, Fiscal Commission Act S. 4173, Dollar-for-Dollar Deficit Reduction Act S. 4174, A bill to provide a premium payment to employees who worked without receiving pay during the shutdown of the Department of Homeland Security of 10 percent of the pay the employees should have received during the shutdown.","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":33834,"prefix":null,"prefix_display":null,"first_name":"KURT","nickname":null,"middle_name":null,"last_name":"VORNDRAN","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":3778,"prefix":null,"prefix_display":null,"first_name":"REGINA","nickname":null,"middle_name":null,"last_name":"HUTTER","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":45731,"prefix":null,"prefix_display":null,"first_name":"MATTHEW","nickname":null,"middle_name":null,"last_name":"SOCKNAT","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":138404,"prefix":"mr","prefix_display":"MR.","first_name":"MATTHEW","nickname":null,"middle_name":null,"last_name":"SOWARDS","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":65769,"prefix":null,"prefix_display":null,"first_name":"JENNIFER","nickname":null,"middle_name":null,"last_name":"TYREE","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":71319,"prefix":null,"prefix_display":null,"first_name":"KATHERINE","nickname":null,"middle_name":"C","last_name":"SYBENGA","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":148450,"prefix":null,"prefix_display":null,"first_name":"MARAM","nickname":null,"middle_name":null,"last_name":"ABDELHAMID","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":45,"name":"Commodity Futures Trading Commission (CFTC)"},{"id":255,"name":"Consumer Financial Protection Bureau (CFPB)"},{"id":135,"name":"Food & Drug Administration (FDA)"},{"id":201,"name":"Homeland Security, Dept of (DHS)"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":18,"name":"Office of Management & Budget (OMB)"},{"id":81,"name":"Office of Personnel Management (OPM)"},{"id":113,"name":"Patent & Trademark Office (PTO)"},{"id":88,"name":"Securities & Exchange Commission (SEC)"},{"id":1,"name":"SENATE"},{"id":41,"name":"Treasury, Dept of"},{"id":184,"name":"U.S. Customs & Border Protection"}]},{"general_issue_code":"GOV","general_issue_code_display":"Government Issues","description":"H. Res. 186, Of inquiry requesting the President to transmit certain documents to the House of Representatives relating to the conflicts of interest of Elon Musk and related information. H. Res. 187, Of inquiry requesting the President to transmit certain information to the House of Representatives referring to the termination, removal, placement on administrative leave, moved to another department of Federal employees and Inspectors General of agencies. H. Res. 259, Of inquiry requesting the President to provide certain documents in the President's possession to the House of Representatives relating to the access provided to the staff and advisers of, including any individual working for or in conjunction with, the Department of Government Efficiency to the systems, applications, and accounts, and any information contained therein, of the Bureau of Consumer Financial Protection. H. Res. 286, Of inquiry requesting the President to transmit certain documents relating to the dangerous, unaccountable use of AI by the United States DOGE Service to jeopardize the private information and essential services of the American people. H. Res. 302, Of inquiry requesting the President and directing the Secretaries of the Treasury and Labor to transmit, respectively, certain documents to the House of Representatives relating to the effect on local economies and communities of the Department of Government Efficiency and newly-imposed tariffs. H. Res. 807, Of inquiry requesting the President to transmit certain information to the House of Representatives referring to the firings, dismissal, reduction in force, or withholding of pay for the period of the lapse in appropriations of furloughed employees of the United States Government. H. Res. 825, Of inquiry requesting the President to transmit certain information to the House of Representatives referring to United States Government agencies sharing certain communications with the public and Federal employees. H.R. 15, Equality Act S. 1503, Equality Act H.R. 25, Fair Tax Act of 2025 H.R. 51, Washington, D.C. Admission Act S. 51, Washington, D.C. Admission Act H.R. 107, Return to Work Act H.R. 195, CBP Relocation Act H.R. 200, Federal Freeze Act S. 357, Federal Freeze Act H.R. 201, Federal Employee Performance and Accountability Act of 2025 S. 359, Federal Employee Performance and Accountability Act of 2025 H.R. 202, Commission to Relocate the Federal Bureaucracy Act S. 353, Commission to Relocate the Federal Bureaucracy Act H.R. 236, Federal Employee Return to Work Act S. 27, Federal Employee Return to Work Act H.R. 242, MANAGER Act H.R. 357, Back to Work Act H.R. 371, No Hires for the Delinquent IRS Act H.R. 435, Direct Hire To Fight Fires H.R. 473, SHOW UP Act of 2025 S. 354, SHOW UP Act of 2025 H.R. 489, Federal Agency Sunset Commission Act of 2025 H.R. 491, Equal COLA Act S. 624, Equal COLA Act H.R. 492, Saving the Civil Service Act S. 134, Saving the Civil Service Act H.R. 493, FAIR Act S. 126,FAIR Act H.R. 514, SWAMP Act S. 22, SWAMP Act H.R. 687, MERIT Act of 2025 S. 662,MERIT Act of 2025 H.R. 697, End the Deep State Act H.R. 743, Tim's Act S. 279, Tim's Act H.R. 759, Federal Firefighters Families First Act H.R. 800, DEI to DIE Act H.R. 925, Dismantle DEI Act S. 382, Dismantle DEI Act of 2025 H.R. 977, Support Military Spouses Act H.R. 1075, Tax Administration Simplification Act H.R. 1101, Taxpayer Data Protection Act H.R. 1280, DRAIN THE SWAMP Act S. 23, DRAIN THE SWAMP Act H.R. 1294, BEST Facilitation Act S. 578, BEST Facilitation Act H.R. 1295, Reorganizing Government Act of 2025 S. 583, Reorganizing Government Act of 2025 H.R. 1460, Drain the Swamp Act of 2025 H.R. 1511, REDUCE Act H.R. 1522, Federal Retirement Fairness Act H.R. 1535, BAD DOGE ACT H.R. 1548, Leveling the Playing Field 2.0 Act S. 691, Leveling the Playing Field 2.0 Act H.R. 1569, CATCH Fentanyl Act S. 703, CATCH Fentanyl Act H.R. 1571, Bureaucratic Labor Adjustment and Downsizing Effort Act H.R. 1603, Repeal CFPB Act H.R. 1637, Protect Veteran Jobs Act S. 914, Protect Veteran Jobs Act H.R. 1807, Protecting Federal Agencies and Employees from Political Interference Act H.R. 1835, MERIT Act S. 1075, MERIT Act H.R. 1930, Border Workforce Improvement Act H.R. 1943, Wildland Firefighter Paycheck Protection Act of 2025 H.R. 1989, Protect Our Probationary Employees Act S. 918, Protect Our Probationary Employees Act H.R. 2006, DOGE Act H.R. 2207, Saving DOEs Workforce Act H.R. 2255, Federal Law Enforcement Officer Service Weapon Purchase Act H.R. 2285, DHS Basic Training Accreditation Improvement Act of 2025 H.R. 2324, Unity through Service Act of 2025 S. 1120, Unity through Service Act of 2025 H.R. 2421, Protecting Taxpayer Resources Act H.R. 2470, COST of Relocations Act S. 1171, COST of Relocations Act H.R. 2532, To prohibit certain removals of employees of the Department of Health and Human Services and sub-agencies and operating divisions thereof, and for other purposes. H.R. 2601, Delete DOGE Act H.R. 2677, 10th Amendment Restoration Act of 2025 H.R. 2737, ELON MUSK Act H.R. 2742, DOGE Accountability and Transparency Act H.R. 2743, Raise the Wage Act of 2025 S. 1332, Raise the Wage Act of 2025 H.R. 2829, SERVICE Act H.R. 2880, To provide employment protections for, and reinstatement of, certain probationary Federal career employees, and for other purposes. H.R. 2894, SEER Act of 2025 S. 1491, SEER Act 2025 H.R. 2905, Ensuring Agency Service Quality Act H.R. 2906, SERVICE Act H.R. 2921, Federal Firefighter Cancer Detection and Prevention Act of 2025 H.R. 2962, Border Airport Fairness Act of 2025 S. 677, Border Airport Fairness Act of 2025 H.R. 3046, Workers Memorial Day H.R. 3072, DOGE Codification Act of 2025 H.R. 3093, REHIRE Act H.R. 3094, PREP Act H.R. 3120, To improve the review and effectiveness of the cost of living adjustments to pay and benefits for members of the Armed Forces and civilian employees of the Department of Defense whose permanent duty station is located in the 19th Congressional District of California, and for other purposes. H.R. 3144, Honoring our K9 Heroes Act H.R. 3170, Improving Access to Workers Compensation for Injured Federal Workers Act H.R. 3171, Reduction in Force Review Act S. 1585, Reduction in Force Review Act H.R. 3226, Law Enforcement Officers Equity Act H.R. 3267, PSLF Payment Completion Fairness Act S. 3487, PSLF Payment Completion Fairness Act H.R. 3305, LEO Fair Retirement Act of 2025 H.R. 3317, Honoring Civil Servants Killed in the Line of Duty Act S. 2078, Honoring Civil Servants Killed in the Line of Duty Act H.R. 3346, Sovereign State Environmental Quality Assurance Act H.R. 3364, Federal Retirement Thrift Investment Board Inspector General Act of 2025 H.R. 3404, FAIR Leave Act H.R. 3435, Federal Cyber Workforce Training Act of 2025 H.R. 3445, Bureau of Consumer Financial Protection Commission Act H.R. 3468, Protecting Retirement and Health Benefits for Families Act H.R. 3555, Protect our Parks Act of 2025 H.R. 3560, Veteran Wildland Firefighter Employment Act of 2025 H.R. 3733, Make DOGE Permanent Act H.R. 3853, Federal Government Reform Act of 2025 H.R. 3891, Northern Border Security and Staffing Reform Act H.R. 3965, PEARL Act S. 4079, PEARL Act H.R. 4052, Employment Abundance Act H.R. 4057, CBP Canine Home Kenneling Pilot Act H.R. 4176, No Secret Police Act of 2025 H.R. 4440, Protecting Federal Employee Rights to Personnel Files Act of 2025 H.R. 4582, To amend the Family and Medical Leave Act of 1993 and title 5, United States Code, to clarify that organ donation surgery qualifies as a serious health condition. H.R. 4672, To extend the break-in-service consideration for firefighter retirements, and other purposes. H.R. 4683, Securing Americas Ports of Entry Act of 2025 S. 1678, Securing America's Ports of Entry Act of 2025 H.R. 4727, To codify Executive Order 14235 relating to restoring public service loan forgiveness. H.R. 4823, Promoting Free and Fair Elections Act of 2025 H.R. 4854, Saving the Department of the Interior's Workforce Act S. 2597, Saving the Department of the Interior's Workforce Act H.R. 4893, National Guard and Reserve Student Loan Fairness Act H.R. 4907, Statistical Agency Integrity and Independence Act H.R. 4908, Time Off to Vote Act S. 2549, Time Off to Vote Act H.R. 4974, DETECT Act of 2025 H.R. 4996, FORWARD Act H.R. 5000, Cybersecurity Hiring Modernization Act H.R. 5091, To amend section 5545 of title 5, United States Code, to provide hazard pay for carrying out prescribed burns, and for other purposes. H.R. 5397, HEALING Mothers and Fathers Act S. 2418, HEALING Mothers and Fathers Act H.R. 5572, Help FEDS Act S. 2948, Help FEDS Act H.R. 5599, To prohibit the removal of Federal employees during any lapse in discretionary appropriations, and for other purposes. H.R. 5653, Trust Through Transparency Act of 2025 H.R. 5674, Emergency Relief for Federal Workers Act of 2025 S. 2966, Emergency Relief for Federal Workers Act of 2025 H.R. 5676, Stop Stealing Our Jobs Act H.R. 5679, TRUMP Act H.R. 5689, Shutdown Guidance for Financial Institutions Act S. 2995, Shutdown Guidance for Financial Institutions Act H.R. 5708, Federal Employees Civil Relief Act S. 2982, Federal Employees Civil Relief Act H.R. 5720, Federal Worker Childcare Protection Act of 2025 H.R. 5724, FAST Justice Act S. 2977, FAST Justice Act H.R. 5750, EQUALS Act of 2025 H.R. 5771, Reliable Social Security Service for Seniors Act H.R. 5810, Federal Supervisor Education Act H.R. 5816, HELP FEDs Act H.R. 5843, Shutdown Student Loans for Feds Act S. 3070, Shutdown Student Loans for Feds Act H.R. 5908, Non-Essential Workers Transparency Act S. 3005, Non-Essential Workers Transparency Act H.R. 6023, Government Shutdown Efficiency Act H.R. 6284, Strengthening Loan Forgiveness for Public Service Workers Act S. 3277, Strengthening Loan Forgiveness for Public Service Workers Act H.R. 6323, Taxpayer Protection and Preparer Proficiency Act H.R. 6330, Federal Relocation Payment Improvement Act H.R. 6371, No Robot Bosses Act H.R. 6548, DHS Suicide Prevention and Resiliency for Law Enforcement Act H.R. 6791, Strong Ports, Strong Communities Act S. 3504, Strong Ports, Strong Communities Act H.R. 6818, Part-Time Worker Bill of Rights Act S. 3547, Part-Time Worker Bill of Rights Act H.R. 6926, Federal Property Integrity Act H.R. 6929, Thrift Savings Plan Emergency Withdrawal Act of 2025 H.R. 6971, To require congressional approval of major Executive Orders and major rules, and for other purposes. H.R. 7039, SERVE Act S. 3622, SERVE Act H.R. 7067, No Violent Criminals in the Federal Workforce Act H.R. 7098, Homeland Threat Response Act H.R. 7102, Federal Workforce Civics Competency and Accountability Act H.R. 7228, Maintain Access to Vital Social Security Services Act of 2026 H.R. 7256, Federal Workforce Early Separation Incentives Act H.R. 7357, TSP Fiduciary Security Act of 2026 S. 1368, TSP Fiduciary Security Act of 2025 H.R. 7471, Give America a Raise Act H.R. 7480, FAIR Act S. 3823, FAIR Act H.R. 7505, Flexible Leave Act H.R. 7507, Fiscal Harms of Federal Firings Act S. 3844, Fiscal Harms of Federal Firing Act H.R. 7531, Healthy Families Act S. 3869, Healthy Families Act H.R. 7583, BE HEARD in the Workplace Act S. 3865, BE HEARD in the Workplace Act H.R. 7706, Federal Retirement Safety Act H.R. 7934, Settlement Agreement Information Database Act of 2026 H.R. 7971, Taxpayer Experience Improvement Act H.R. 7972, Taxpayer Workforce Modernization Act H.R. 8096, Duplication Scoring Act of 2026 H.R. 8134, Strengthen Taxpayer Rights Act of 2026 S. Res. 165, A resolution expressing the sense of the Senate that the plan of President Trump and Elon Musk to fire 83,000 employees of the Department of Veterans Affairs is unacceptable and must be rescinded. S. Res. 166, A resolution demanding the immediate reinstatement of all veteran Federal employees involuntarily removed or otherwise dismissed without cause since January 20, 2025. S. Res. 324, A resolution expressing the sense of the Senate that the actions of the Trump Administration that drastically and indiscriminately reduce staff at Federal agencies, freeze vast swaths of critical Federal funding, and dismantle Federal agencies are destructive and harmful to communities across the United States and have raised costs for American families. S. Res. 579, A resolution affirming the importance of the Social Security program to the people of the United States and expressing the sense of the Senate that Social Security must be preserved, protected, and strengthened for current and future generations. S. 21, REMOTE Act S. 26, To exclude locality adjustments from average pay for computing retirement annuities of new employees. S. 67, Censorship Accountability Act S. 82, Telework Reform Act of 2025 S. 102, ROOMIE Act S. 135, Wildland Firefighter Paycheck Protection Act of 2025 S. 295, Reducing the Federal Workforce Through Attrition Act S. 452, BARCODE Efficiency Act S. 490,Protecting Americans' Privacy Act S. 591, Restore Merit to Government Service Act of 2025 S. 727, U.S. Customs and Border Protection Officer Retirement Technical Corrections Act S. 949, Save Our Parks Act of 2025 S. 1059, One Agency Act S. 1138, A bill to require the Secretary of Homeland Security to enhance capabilities for outbound inspections at the southern land border, and for other purposes. S. 1154, Congressional Whistleblower Protection Act of 2025 S. 1185, FIGHTING for America Act of 2025 S. 1427, Audit the IRS Act S. 1444, Tax DODGER Act S. 1625, SHIELD Against CCP Act S. 1768, TALENTS Act S. 1771, Larry Henderson Act S. 1819, DOGE BROS Act S. 1871, Emerging Innovative Border Technologies Act S. 1923, CFPB Pay Fairness Act of 2025 S. 1991, Delivering On Government Efficiency in Spending Act S. 2039, Wildfire Risk Evaluation Act S. 2091, Restoring Lethality Act S. 2163, Border Patrol Recruitment Enhancement Act S. 2173, For Sale Act of 2025 S. 2429, Stop the Scammers Act S. 2473, Federal Firefighters Families First Act S. 2542, Federal Building Threat Notification Act S. 2595, Saving the Department of Energy's Workforce Act S. 2605, A bill to amend title 10, United States Code, to improve recruitment and retention of the cyber workforce of the Department of Defense, and for other purposes. S. 2645, DHS Suicide Prevention and Resiliency for Law Enforcement Act S. 2732, Bonuses for Cost-Cutters Act of 2025 S. 2786, Pipeline to Service Act S. 2816, Stop Sycophants in Government Act of 2025 S. 2838, Protecting Our Democracy Act S. 2953, Dismantling Double Dippers Act of 2025 S. 3091, DISPOSAL Act S. 3141, SAFE Act S. 3156, Federal Worker Mortgage Forbearance Act S. 3263, Stop TSP ESG Act S. 3283, Exclusive Citizenship Act of 2025 S. 3296, Improving Access to Workers Compensation for Injured Federal Workers Act of 2025 S. 3553, Wheres WALDO Act S. 3609, Community Protection and Wildfire Resilience Act S. 3619, Department of Defense Comprehensive Cyber Workforce Strategy Act of 2026 S. 3699, FOCUS Act S. 3755, Digital Commodity Intermediaries Act S. 3996, DHS Hiring Review Act S. 3997, Homeland Security Improvement Act S. 4099, Whistleblower Anti-Gag Act of 2026 S. 4100, A bill to amend title 5, United States Code, to clarify whistleblower protections for duty speech disclosures, and for other purposes. S. 4117, Federal Law Enforcement Officer Service Weapon Purchase Act of 2026 S. 4271, A bill to amend title 5, United States Code, to provide rest and recuperation leave for employees engaged in wildland firefighting, and for other purposes.","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":33834,"prefix":null,"prefix_display":null,"first_name":"KURT","nickname":null,"middle_name":null,"last_name":"VORNDRAN","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":3778,"prefix":null,"prefix_display":null,"first_name":"REGINA","nickname":null,"middle_name":null,"last_name":"HUTTER","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":45731,"prefix":null,"prefix_display":null,"first_name":"MATTHEW","nickname":null,"middle_name":null,"last_name":"SOCKNAT","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":138404,"prefix":"mr","prefix_display":"MR.","first_name":"MATTHEW","nickname":null,"middle_name":null,"last_name":"SOWARDS","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":65769,"prefix":null,"prefix_display":null,"first_name":"JENNIFER","nickname":null,"middle_name":null,"last_name":"TYREE","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":71319,"prefix":null,"prefix_display":null,"first_name":"KATHERINE","nickname":null,"middle_name":"C","last_name":"SYBENGA","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":148450,"prefix":null,"prefix_display":null,"first_name":"MARAM","nickname":null,"middle_name":null,"last_name":"ABDELHAMID","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":45,"name":"Commodity Futures Trading Commission (CFTC)"},{"id":255,"name":"Consumer Financial Protection Bureau (CFPB)"},{"id":33,"name":"Energy, Dept of"},{"id":63,"name":"Federal Retirement Thrift Investment Board"},{"id":135,"name":"Food & Drug Administration (FDA)"},{"id":65,"name":"General Services Administration (GSA)"},{"id":34,"name":"Health & Human Services, Dept of (HHS)"},{"id":201,"name":"Homeland Security, Dept of (DHS)"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":67,"name":"Merit Systems Protection Board"},{"id":71,"name":"Natl Credit Union Administration (NCUA)"},{"id":143,"name":"Natl Park Service (NPS)"},{"id":18,"name":"Office of Management & Budget (OMB)"},{"id":81,"name":"Office of Personnel Management (OPM)"},{"id":82,"name":"Office of Special Counsel"},{"id":183,"name":"Office of the Comptroller of the Currency (OCC)"},{"id":113,"name":"Patent & Trademark Office (PTO)"},{"id":88,"name":"Securities & Exchange Commission (SEC)"},{"id":1,"name":"SENATE"},{"id":41,"name":"Treasury, Dept of"},{"id":184,"name":"U.S. Customs & Border Protection"},{"id":12,"name":"White House Office"}]},{"general_issue_code":"HCR","general_issue_code_display":"Health Issues","description":"H.R. 1287, Fix FEDVIP Age Act H.R. 1597, Compassion for Vulnerable and Struggling Workers Act H.R. 1670, Family Building FEHB Fairness Act S. 797, The Family Building FEHB Fairness Act H.R. 2193, FEHB Protection Act of 2025 H.R. 4409, Fair Pharmacies for Federal Employees Act of 2025 H.R. 4648, Access to Fertility Treatment and Care Act S. 2408, Access to Fertility Treatment and Care Act H.R. 5127, PrEP and PEP are Prevention Act H.R. 6610, Pharmacists Fight Back [in Federal Employee Health Benefit Plans Act]","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":33834,"prefix":null,"prefix_display":null,"first_name":"KURT","nickname":null,"middle_name":null,"last_name":"VORNDRAN","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":3778,"prefix":null,"prefix_display":null,"first_name":"REGINA","nickname":null,"middle_name":null,"last_name":"HUTTER","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":45731,"prefix":null,"prefix_display":null,"first_name":"MATTHEW","nickname":null,"middle_name":null,"last_name":"SOCKNAT","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":65769,"prefix":null,"prefix_display":null,"first_name":"JENNIFER","nickname":null,"middle_name":null,"last_name":"TYREE","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":138404,"prefix":"mr","prefix_display":"MR.","first_name":"MATTHEW","nickname":null,"middle_name":null,"last_name":"SOWARDS","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":71319,"prefix":null,"prefix_display":null,"first_name":"KATHERINE","nickname":null,"middle_name":"C","last_name":"SYBENGA","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":148450,"prefix":null,"prefix_display":null,"first_name":"MARAM","nickname":null,"middle_name":null,"last_name":"ABDELHAMID","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":2,"name":"HOUSE 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Res. 432, Providing for consideration of the bill (H.R. 2550) to nullify the Executive Order relating to Exclusions from Federal Labor-Management Relations Programs, and for other purposes. H.R. 20, Richard L. Trumka Protecting the Right to Organize Act of 2025 S. 852, Richard L. Trumka Protecting the Right to Organize Act of 2025 H.R. 1210, Protecting Taxpayers' Wallets Act of 2025 S. 511, Protecting Taxpayers' Wallets Act of 2025 H.R. 2086, Rights for the TSA Workforce Act S. 997, Rights for the TSA Workforce Act H.R. 2174, The Paycheck Protection Act S. 1597, Paycheck Protection Act H.R. 2249, Preserving Presidential Management Authority Act H.R 2297, Taxpayer-Funded Union Time Transparency Act S. 1170, Taxpayer-Funded Union Time Transparency Act H.R. 2550, Protect America's Workforce Act S. 2837, Protect Americas Workforce Act H.R. 2671, Tax Fairness for Workers Act S. 1286, Tax Fairness for Workers Act H.R. 2676, No Union Time on the Taxpayers Dime Act S. 1313, No Union Time on the Taxpayer's Dime Act H.R. 5749, Official Time Reporting Act H.R. 6136, PURE Act H.R. 6139, Union Members Right to Know Act S. 3114, Union Members Right to Know Act H.R. 6156, Endorsement Transparency Act S. 1006, Federal Workforce Freedom Act S. 3766, Make Congress Drive Union Made Act","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":33834,"prefix":null,"prefix_display":null,"first_name":"KURT","nickname":null,"middle_name":null,"last_name":"VORNDRAN","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":3778,"prefix":null,"prefix_display":null,"first_name":"REGINA","nickname":null,"middle_name":null,"last_name":"HUTTER","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":45731,"prefix":null,"prefix_display":null,"first_name":"MATTHEW","nickname":null,"middle_name":null,"last_name":"SOCKNAT","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":138404,"prefix":"mr","prefix_display":"MR.","first_name":"MATTHEW","nickname":null,"middle_name":null,"last_name":"SOWARDS","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":65769,"prefix":null,"prefix_display":null,"first_name":"JENNIFER","nickname":null,"middle_name":null,"last_name":"TYREE","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":71319,"prefix":null,"prefix_display":null,"first_name":"KATHERINE","nickname":null,"middle_name":"C","last_name":"SYBENGA","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":148450,"prefix":null,"prefix_display":null,"first_name":"MARAM","nickname":null,"middle_name":null,"last_name":"ABDELHAMID","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":255,"name":"Consumer Financial Protection Bureau (CFPB)"},{"id":53,"name":"Federal Communications Commission (FCC)"},{"id":34,"name":"Health & Human Services, Dept of (HHS)"},{"id":201,"name":"Homeland Security, Dept of (DHS)"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":38,"name":"Labor, Dept of (DOL)"},{"id":143,"name":"Natl Park Service (NPS)"},{"id":18,"name":"Office of Management & Budget (OMB)"},{"id":81,"name":"Office of Personnel Management (OPM)"},{"id":1,"name":"SENATE"},{"id":12,"name":"White House Office"}]}],"conviction_disclosures":[],"foreign_entities":[],"affiliated_organizations":[]},{"url":"https://lda.gov/api/v1/filings/e00c4483-52f0-44d5-abb7-5c8ace4762a2/","filing_uuid":"e00c4483-52f0-44d5-abb7-5c8ace4762a2","filing_type":"Q1","filing_type_display":"1st Quarter - 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Con. Res. 15, Calling an Article V Convention for proposing a Fiscal Responsibility Amendment to the United States Constitution and stipulating ratification by a vote of We the People, and for other purposes. H. J. Res. 110, Proposing a balanced budget amendment to the Constitution of the United States. H. J. Res. 112, Proposing an amendment to the Constitution of the United States related to the public debt. H. J. Res. 139, Proposing an amendment to the Constitution of the United States requiring a balanced budget for the Federal Government. H.R. 182, Default Prevention Act H.R. 191, Inflation Reduction Act of 2025 H.R. 196, Family and Small Business Taxpayer Protection Act H.R. 199, Implementing DOGE Act H.R. 222, Sustainable Budget Act of 2025 H.R. 374, DIRECT Act H.R. 654, TABS Act of 2025 H.R. 814, Defund the CFPB Act S. 303, Defund the CFPB Act H.R. 1180, To repeal the Impoundment Control Act of 1974. S. 515, A bill to repeal the Impoundment Control Act of 1974. H.R. 1916, Pay Our Border Patrol and Customs Agents Act of 2025 H.R. 2050, Homeland Heroes Pay Act H.R. 3001, To advance commonsense priorities. H.R. 3141, CFPB Budget Integrity Act H.R. 3289, Fiscal Commission Act H.R. 4016, Department of Defense Appropriations Act, 2026 S. 2572, Department of Defense Appropriations Act, 2026 H.R. 4178, Enforce the Caps Act H.R. 4213, Department of Homeland Security Appropriations Act, 2026 H.R. 4229, To amend the Impoundment Control Act of 1974 to require prior approval from Congress before the Comptroller General may pursue a civil action under such Act, and for other purposes. H.R. 4273, Over-the-Counter Monograph Drug User Fee Amendments H.R. 4553, Energy and Water Development and Related Agencies Appropriations Act, 2026 S. 3293, Energy and Water Development and Related Agencies Appropriations Act, 2026 H.R. 4754, Department of the Interior, Environment, and Related Agencies Appropriations Act, 2026 S. 2431, Department of the Interior, Environment, and Related Agencies Appropriations Act, 2026 H.R. 4765, Securing our Border Act H.R. 5130, Prevent Government Shutdowns Act of 2025 S. 2721, Prevent Government Shutdowns Act of 2025 H.R. 5166, Financial Services and General Government Appropriations Act, 2026 S. 3290, Financial Services and General Government Appropriations Act, 2026 H.R. 5220, Congressional Power of the Purse Act H.R. 5260, Pay Our Border Patrol and Customs Agents Act H.R. 5304, Departments of Labor, Health and Human Services, and Education, and Related Agencies Appropriations Act, 2026 S. 2587, Departments of Labor, Health and Human Services, and Education, and Related Agencies Appropriations Act, 2026 H.R. 5342, Commerce, Justice, Science, and Related Agencies Appropriations Act, 2026 S. 2354, Commerce, Justice, Science, and Related Agencies Appropriations Act, 2026 H.R. 5398, Pay Our Homeland Defenders Act of 2026 H.R. 5405, Government Shutdown Prevention Act of 2025 H.R. 5438, Incentivize Savings Act H.R. 5450, Continuing Appropriations and Extensions and Other Matters Act, 2026 S. 2882, Continuing Appropriations and Extensions and Other Matters Act, 2026 H.R. 5542, End Government Shutdowns Act H.R. 5552, Eliminate Shutdowns Act H.R. 5619, Federal Firefighter Paycheck Protection Act H.R. 5628, Pay Workers What Theyve Earned Act H.R. 5801, Shutdown Fairness Act S. 3012, Shutdown Fairness Act H.R. 5802, MAGA Act H.R. 5870, Prevent Government Shutdowns Act H.R. 5893, GUARD Act H.R. 5998, To provide for the continued operation of the Hatch Act Unit of the Office of Special Counsel during a lapse in appropriations, and for other purposes. H.R. 6938, Commerce, Justice, Science; Energy and Water Development; and Interior and Environment Appropriations Act, 2026 H.R. 7006, Financial Services and General Government and National Security, Department of State, and Related Programs Appropriations Act, 2026 H.R. 7137, Shutdown Fairness Act S. 3168, Shutdown Fairness Act H.R. 7147, Further Additional Continuing Appropriations Act, 2026 H.R. 7148, Consolidated Appropriations Act, 2026 H.R. 7295, Comprehensive Congressional Budget Act of 2026 H.R. 7322, True Shutdown Fairness Act H.R. 7481, Department of Homeland Security Appropriations Act, 2026 H.R. 7617, To provide funding for administrative expenses of the Department of Homeland Security during any lapse in appropriations during fiscal year 2026, to require that the Department be responsive to congressional offices during such a lapse in appropriations, and for other purposes. H.R. 7744, Department of Homeland Security Appropriations Act, 2026 H.R. 7844, To provide the Secretary of Homeland Security with the authority to transfer funds between accounts under the Department of Homeland Security during a lapse in appropriations, and for other purposes. H.R. 8029, Pay Our Homeland Defenders Act S. J. Res. 97, A joint resolution proposing a balanced budget amendment to the Constitution of the United States. S. Res. 654, A resolution expressing the sense of the Senate that the United States should reduce and maintain the Federal unified budget deficit at or below 3 percent of gross domestic product. S. 175, A bill to rescind unobligated balances appropriated for the IRS and use for an External Revenue Service S. 181, A bill to require agencies submit zero-based budgets. S. 360, To provide for across the board rescissions of non-security discretionary spending S. 481, Securing our Border Act S. 2806, Eliminate Shutdowns Act S. 3001, Shutdown Fairness Act S. 3039, True Shutdown Fairness Act S. 3165, True Shutdown Fairness Act S. 3043, Military and Federal Employee Protection Act S. 3066, Pay the People Act S. 3681, Keep Our Border Agents Paid Act S. 3951, Balanced Budget Responsibility Act of 2026 S. 4012, Fiscal Commission Act S. 4173, Dollar-for-Dollar Deficit Reduction Act S. 4174, A bill to provide a premium payment to employees who worked without receiving pay during the shutdown of the Department of Homeland Security of 10 percent of the pay the employees should have received during the shutdown.","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":33834,"prefix":null,"prefix_display":null,"first_name":"KURT","nickname":null,"middle_name":null,"last_name":"VORNDRAN","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":3778,"prefix":null,"prefix_display":null,"first_name":"REGINA","nickname":null,"middle_name":null,"last_name":"HUTTER","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":45731,"prefix":null,"prefix_display":null,"first_name":"MATTHEW","nickname":null,"middle_name":null,"last_name":"SOCKNAT","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":138404,"prefix":"mr","prefix_display":"MR.","first_name":"MATTHEW","nickname":null,"middle_name":null,"last_name":"SOWARDS","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":65769,"prefix":null,"prefix_display":null,"first_name":"JENNIFER","nickname":null,"middle_name":null,"last_name":"TYREE","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":71319,"prefix":null,"prefix_display":null,"first_name":"KATHERINE","nickname":null,"middle_name":"C","last_name":"SYBENGA","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":148450,"prefix":null,"prefix_display":null,"first_name":"MARAM","nickname":null,"middle_name":null,"last_name":"ABDELHAMID","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":45,"name":"Commodity Futures Trading Commission (CFTC)"},{"id":255,"name":"Consumer Financial Protection Bureau (CFPB)"},{"id":135,"name":"Food & Drug Administration (FDA)"},{"id":201,"name":"Homeland Security, Dept of (DHS)"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":188,"name":"Internal Revenue Service (IRS)"},{"id":18,"name":"Office of Management & Budget (OMB)"},{"id":81,"name":"Office of Personnel Management (OPM)"},{"id":113,"name":"Patent & Trademark Office (PTO)"},{"id":88,"name":"Securities & Exchange Commission (SEC)"},{"id":1,"name":"SENATE"},{"id":41,"name":"Treasury, Dept of"},{"id":184,"name":"U.S. Customs & Border Protection"}]},{"general_issue_code":"GOV","general_issue_code_display":"Government Issues","description":"H. Res. 186, Of inquiry requesting the President to transmit certain documents to the House of Representatives relating to the conflicts of interest of Elon Musk and related information. H. Res. 187, Of inquiry requesting the President to transmit certain information to the House of Representatives referring to the termination, removal, placement on administrative leave, moved to another department of Federal employees and Inspectors General of agencies. H. Res. 259, Of inquiry requesting the President to provide certain documents in the President's possession to the House of Representatives relating to the access provided to the staff and advisers of, including any individual working for or in conjunction with, the Department of Government Efficiency to the systems, applications, and accounts, and any information contained therein, of the Bureau of Consumer Financial Protection. H. Res. 286, Of inquiry requesting the President to transmit certain documents relating to the dangerous, unaccountable use of AI by the United States DOGE Service to jeopardize the private information and essential services of the American people. H. Res. 302, Of inquiry requesting the President and directing the Secretaries of the Treasury and Labor to transmit, respectively, certain documents to the House of Representatives relating to the effect on local economies and communities of the Department of Government Efficiency and newly-imposed tariffs. H. Res. 807, Of inquiry requesting the President to transmit certain information to the House of Representatives referring to the firings, dismissal, reduction in force, or withholding of pay for the period of the lapse in appropriations of furloughed employees of the United States Government. H. Res. 825, Of inquiry requesting the President to transmit certain information to the House of Representatives referring to United States Government agencies sharing certain communications with the public and Federal employees. H.R. 15, Equality Act S. 1503, Equality Act H.R. 25, Fair Tax Act of 2025 H.R. 51, Washington, D.C. Admission Act S. 51, Washington, D.C. Admission Act H.R. 107, Return to Work Act H.R. 195, CBP Relocation Act H.R. 200, Federal Freeze Act S. 357, Federal Freeze Act H.R. 201, Federal Employee Performance and Accountability Act of 2025 S. 359, Federal Employee Performance and Accountability Act of 2025 H.R. 202, Commission to Relocate the Federal Bureaucracy Act S. 353, Commission to Relocate the Federal Bureaucracy Act H.R. 236, Federal Employee Return to Work Act S. 27, Federal Employee Return to Work Act H.R. 242, MANAGER Act H.R. 357, Back to Work Act H.R. 371, No Hires for the Delinquent IRS Act H.R. 435, Direct Hire To Fight Fires H.R. 473, SHOW UP Act of 2025 S. 354, SHOW UP Act of 2025 H.R. 489, Federal Agency Sunset Commission Act of 2025 H.R. 491, Equal COLA Act S. 624, Equal COLA Act H.R. 492, Saving the Civil Service Act S. 134, Saving the Civil Service Act H.R. 493, FAIR Act S. 126,FAIR Act H.R. 514, SWAMP Act S. 22, SWAMP Act H.R. 687, MERIT Act of 2025 S. 662,MERIT Act of 2025 H.R. 697, End the Deep State Act H.R. 743, Tim's Act S. 279, Tim's Act H.R. 759, Federal Firefighters Families First Act H.R. 800, DEI to DIE Act H.R. 925, Dismantle DEI Act S. 382, Dismantle DEI Act of 2025 H.R. 977, Support Military Spouses Act H.R. 1075, Tax Administration Simplification Act H.R. 1101, Taxpayer Data Protection Act H.R. 1280, DRAIN THE SWAMP Act S. 23, DRAIN THE SWAMP Act H.R. 1294, BEST Facilitation Act S. 578, BEST Facilitation Act H.R. 1295, Reorganizing Government Act of 2025 S. 583, Reorganizing Government Act of 2025 H.R. 1460, Drain the Swamp Act of 2025 H.R. 1511, REDUCE Act H.R. 1522, Federal Retirement Fairness Act H.R. 1535, BAD DOGE ACT H.R. 1548, Leveling the Playing Field 2.0 Act S. 691, Leveling the Playing Field 2.0 Act H.R. 1569, CATCH Fentanyl Act S. 703, CATCH Fentanyl Act H.R. 1571, Bureaucratic Labor Adjustment and Downsizing Effort Act H.R. 1603, Repeal CFPB Act H.R. 1637, Protect Veteran Jobs Act S. 914, Protect Veteran Jobs Act H.R. 1807, Protecting Federal Agencies and Employees from Political Interference Act H.R. 1835, MERIT Act S. 1075, MERIT Act H.R. 1930, Border Workforce Improvement Act H.R. 1943, Wildland Firefighter Paycheck Protection Act of 2025 H.R. 1989, Protect Our Probationary Employees Act S. 918, Protect Our Probationary Employees Act H.R. 2006, DOGE Act H.R. 2207, Saving DOEs Workforce Act H.R. 2255, Federal Law Enforcement Officer Service Weapon Purchase Act H.R. 2285, DHS Basic Training Accreditation Improvement Act of 2025 H.R. 2324, Unity through Service Act of 2025 S. 1120, Unity through Service Act of 2025 H.R. 2421, Protecting Taxpayer Resources Act H.R. 2470, COST of Relocations Act S. 1171, COST of Relocations Act H.R. 2532, To prohibit certain removals of employees of the Department of Health and Human Services and sub-agencies and operating divisions thereof, and for other purposes. H.R. 2601, Delete DOGE Act H.R. 2677, 10th Amendment Restoration Act of 2025 H.R. 2737, ELON MUSK Act H.R. 2742, DOGE Accountability and Transparency Act H.R. 2743, Raise the Wage Act of 2025 S. 1332, Raise the Wage Act of 2025 H.R. 2829, SERVICE Act H.R. 2880, To provide employment protections for, and reinstatement of, certain probationary Federal career employees, and for other purposes. H.R. 2894, SEER Act of 2025 S. 1491, SEER Act 2025 H.R. 2905, Ensuring Agency Service Quality Act H.R. 2906, SERVICE Act H.R. 2921, Federal Firefighter Cancer Detection and Prevention Act of 2025 H.R. 2962, Border Airport Fairness Act of 2025 S. 677, Border Airport Fairness Act of 2025 H.R. 3046, Workers Memorial Day H.R. 3072, DOGE Codification Act of 2025 H.R. 3093, REHIRE Act H.R. 3094, PREP Act H.R. 3120, To improve the review and effectiveness of the cost of living adjustments to pay and benefits for members of the Armed Forces and civilian employees of the Department of Defense whose permanent duty station is located in the 19th Congressional District of California, and for other purposes. H.R. 3144, Honoring our K9 Heroes Act H.R. 3170, Improving Access to Workers Compensation for Injured Federal Workers Act H.R. 3171, Reduction in Force Review Act S. 1585, Reduction in Force Review Act H.R. 3226, Law Enforcement Officers Equity Act H.R. 3267, PSLF Payment Completion Fairness Act S. 3487, PSLF Payment Completion Fairness Act H.R. 3305, LEO Fair Retirement Act of 2025 H.R. 3317, Honoring Civil Servants Killed in the Line of Duty Act S. 2078, Honoring Civil Servants Killed in the Line of Duty Act H.R. 3346, Sovereign State Environmental Quality Assurance Act H.R. 3364, Federal Retirement Thrift Investment Board Inspector General Act of 2025 H.R. 3404, FAIR Leave Act H.R. 3435, Federal Cyber Workforce Training Act of 2025 H.R. 3445, Bureau of Consumer Financial Protection Commission Act H.R. 3468, Protecting Retirement and Health Benefits for Families Act H.R. 3555, Protect our Parks Act of 2025 H.R. 3560, Veteran Wildland Firefighter Employment Act of 2025 H.R. 3733, Make DOGE Permanent Act H.R. 3853, Federal Government Reform Act of 2025 H.R. 3891, Northern Border Security and Staffing Reform Act H.R. 3965, PEARL Act S. 4079, PEARL Act H.R. 4052, Employment Abundance Act H.R. 4057, CBP Canine Home Kenneling Pilot Act H.R. 4176, No Secret Police Act of 2025 H.R. 4440, Protecting Federal Employee Rights to Personnel Files Act of 2025 H.R. 4582, To amend the Family and Medical Leave Act of 1993 and title 5, United States Code, to clarify that organ donation surgery qualifies as a serious health condition. H.R. 4672, To extend the break-in-service consideration for firefighter retirements, and other purposes. H.R. 4683, Securing Americas Ports of Entry Act of 2025 S. 1678, Securing America's Ports of Entry Act of 2025 H.R. 4727, To codify Executive Order 14235 relating to restoring public service loan forgiveness. H.R. 4823, Promoting Free and Fair Elections Act of 2025 H.R. 4854, Saving the Department of the Interior's Workforce Act S. 2597, Saving the Department of the Interior's Workforce Act H.R. 4893, National Guard and Reserve Student Loan Fairness Act H.R. 4907, Statistical Agency Integrity and Independence Act H.R. 4908, Time Off to Vote Act S. 2549, Time Off to Vote Act H.R. 4974, DETECT Act of 2025 H.R. 4996, FORWARD Act H.R. 5000, Cybersecurity Hiring Modernization Act H.R. 5091, To amend section 5545 of title 5, United States Code, to provide hazard pay for carrying out prescribed burns, and for other purposes. H.R. 5397, HEALING Mothers and Fathers Act S. 2418, HEALING Mothers and Fathers Act H.R. 5572, Help FEDS Act S. 2948, Help FEDS Act H.R. 5599, To prohibit the removal of Federal employees during any lapse in discretionary appropriations, and for other purposes. H.R. 5653, Trust Through Transparency Act of 2025 H.R. 5674, Emergency Relief for Federal Workers Act of 2025 S. 2966, Emergency Relief for Federal Workers Act of 2025 H.R. 5676, Stop Stealing Our Jobs Act H.R. 5679, TRUMP Act H.R. 5689, Shutdown Guidance for Financial Institutions Act S. 2995, Shutdown Guidance for Financial Institutions Act H.R. 5708, Federal Employees Civil Relief Act S. 2982, Federal Employees Civil Relief Act H.R. 5720, Federal Worker Childcare Protection Act of 2025 H.R. 5724, FAST Justice Act S. 2977, FAST Justice Act H.R. 5750, EQUALS Act of 2025 H.R. 5771, Reliable Social Security Service for Seniors Act H.R. 5810, Federal Supervisor Education Act H.R. 5816, HELP FEDs Act H.R. 5843, Shutdown Student Loans for Feds Act S. 3070, Shutdown Student Loans for Feds Act H.R. 5908, Non-Essential Workers Transparency Act S. 3005, Non-Essential Workers Transparency Act H.R. 6023, Government Shutdown Efficiency Act H.R. 6284, Strengthening Loan Forgiveness for Public Service Workers Act S. 3277, Strengthening Loan Forgiveness for Public Service Workers Act H.R. 6323, Taxpayer Protection and Preparer Proficiency Act H.R. 6330, Federal Relocation Payment Improvement Act H.R. 6371, No Robot Bosses Act H.R. 6548, DHS Suicide Prevention and Resiliency for Law Enforcement Act H.R. 6791, Strong Ports, Strong Communities Act S. 3504, Strong Ports, Strong Communities Act H.R. 6818, Part-Time Worker Bill of Rights Act S. 3547, Part-Time Worker Bill of Rights Act H.R. 6926, Federal Property Integrity Act H.R. 6929, Thrift Savings Plan Emergency Withdrawal Act of 2025 H.R. 6971, To require congressional approval of major Executive Orders and major rules, and for other purposes. H.R. 7039, SERVE Act S. 3622, SERVE Act H.R. 7067, No Violent Criminals in the Federal Workforce Act H.R. 7098, Homeland Threat Response Act H.R. 7102, Federal Workforce Civics Competency and Accountability Act H.R. 7228, Maintain Access to Vital Social Security Services Act of 2026 H.R. 7256, Federal Workforce Early Separation Incentives Act H.R. 7357, TSP Fiduciary Security Act of 2026 S. 1368, TSP Fiduciary Security Act of 2025 H.R. 7471, Give America a Raise Act H.R. 7480, FAIR Act S. 3823, FAIR Act H.R. 7505, Flexible Leave Act H.R. 7507, Fiscal Harms of Federal Firings Act S. 3844, Fiscal Harms of Federal Firing Act H.R. 7531, Healthy Families Act S. 3869, Healthy Families Act H.R. 7583, BE HEARD in the Workplace Act S. 3865, BE HEARD in the Workplace Act H.R. 7706, Federal Retirement Safety Act H.R. 7934, Settlement Agreement Information Database Act of 2026 H.R. 7971, Taxpayer Experience Improvement Act H.R. 7972, Taxpayer Workforce Modernization Act H.R. 8096, Duplication Scoring Act of 2026 H.R. 8134, Strengthen Taxpayer Rights Act of 2026 S. Res. 165, A resolution expressing the sense of the Senate that the plan of President Trump and Elon Musk to fire 83,000 employees of the Department of Veterans Affairs is unacceptable and must be rescinded. S. Res. 166, A resolution demanding the immediate reinstatement of all veteran Federal employees involuntarily removed or otherwise dismissed without cause since January 20, 2025. S. Res. 324, A resolution expressing the sense of the Senate that the actions of the Trump Administration that drastically and indiscriminately reduce staff at Federal agencies, freeze vast swaths of critical Federal funding, and dismantle Federal agencies are destructive and harmful to communities across the United States and have raised costs for American families. S. Res. 579, A resolution affirming the importance of the Social Security program to the people of the United States and expressing the sense of the Senate that Social Security must be preserved, protected, and strengthened for current and future generations. S. 21, REMOTE Act S. 26, To exclude locality adjustments from average pay for computing retirement annuities of new employees. S. 67, Censorship Accountability Act S. 82, Telework Reform Act of 2025 S. 102, ROOMIE Act S. 135, Wildland Firefighter Paycheck Protection Act of 2025 S. 295, Reducing the Federal Workforce Through Attrition Act S. 452, BARCODE Efficiency Act S. 490,Protecting Americans' Privacy Act S. 591, Restore Merit to Government Service Act of 2025 S. 727, U.S. Customs and Border Protection Officer Retirement Technical Corrections Act S. 949, Save Our Parks Act of 2025 S. 1059, One Agency Act S. 1138, A bill to require the Secretary of Homeland Security to enhance capabilities for outbound inspections at the southern land border, and for other purposes. S. 1154, Congressional Whistleblower Protection Act of 2025 S. 1185, FIGHTING for America Act of 2025 S. 1427, Audit the IRS Act S. 1444, Tax DODGER Act S. 1625, SHIELD Against CCP Act S. 1768, TALENTS Act S. 1771, Larry Henderson Act S. 1819, DOGE BROS Act S. 1871, Emerging Innovative Border Technologies Act S. 1923, CFPB Pay Fairness Act of 2025 S. 1991, Delivering On Government Efficiency in Spending Act S. 2039, Wildfire Risk Evaluation Act S. 2091, Restoring Lethality Act S. 2163, Border Patrol Recruitment Enhancement Act S. 2173, For Sale Act of 2025 S. 2429, Stop the Scammers Act S. 2473, Federal Firefighters Families First Act S. 2542, Federal Building Threat Notification Act S. 2595, Saving the Department of Energy's Workforce Act S. 2605, A bill to amend title 10, United States Code, to improve recruitment and retention of the cyber workforce of the Department of Defense, and for other purposes. S. 2645, DHS Suicide Prevention and Resiliency for Law Enforcement Act S. 2732, Bonuses for Cost-Cutters Act of 2025 S. 2786, Pipeline to Service Act S. 2816, Stop Sycophants in Government Act of 2025 S. 2838, Protecting Our Democracy Act S. 2953, Dismantling Double Dippers Act of 2025 S. 3091, DISPOSAL Act S. 3141, SAFE Act S. 3156, Federal Worker Mortgage Forbearance Act S. 3263, Stop TSP ESG Act S. 3283, Exclusive Citizenship Act of 2025 S. 3296, Improving Access to Workers Compensation for Injured Federal Workers Act of 2025 S. 3553, Wheres WALDO Act S. 3609, Community Protection and Wildfire Resilience Act S. 3619, Department of Defense Comprehensive Cyber Workforce Strategy Act of 2026 S. 3699, FOCUS Act S. 3755, Digital Commodity Intermediaries Act S. 3996, DHS Hiring Review Act S. 3997, Homeland Security Improvement Act S. 4099, Whistleblower Anti-Gag Act of 2026 S. 4100, A bill to amend title 5, United States Code, to clarify whistleblower protections for duty speech disclosures, and for other purposes. S. 4117, Federal Law Enforcement Officer Service Weapon Purchase Act of 2026 S. 4271, A bill to amend title 5, United States Code, to provide rest and recuperation leave for employees engaged in wildland firefighting, and for other 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existence as an independent regulator and insurer of credit unions Support assistance for minority depository institution credit unions Support regulatory relief for de novo credit unions Support harmonization of federal cyber incident notification standards Oppose Community Reinvestment Act requirements for credit unions Oppose legislative action to restrict credit union overdraft and courtesy pay programs Support regulatory framework for artificial intelligence that allows responsible innovation and recognizes credit unions compliance with existing regulations Support allowing use of artificial intelligence for regulatory reporting purposes Support mandatory arbitration agreements Oppose national interest rate cap Oppose national credit card interest rate cap Support Federal Credit Union Act modernization Support expanded natural person and corporate credit union investment authority Support expanded credit union examination cycle Support increased examination transparency Support Central Liquidity Facility and Community Development Revolving Loan Fund enhancements Oppose NCUA examination of credit union vendors Support modification of credit union loan maturity limits Oppose National Credit Union Share Insurance Fund structural changes Oppose National Credit Union Share Insurance Fund premium assessment Support parity in deposit insurance coverage levels between credit unions and banks Oppose additional Call Report fields on loans to credit union officials and senior executive staff Oppose additional Call Report fields on maturity distribution of uninsured shares Oppose making changes to Call Report requirements without using notice-and-comment process Oppose NCUA Call Report collection of overdraft and NSF fee revenue data Support modernization and simplification of Call Report form and instructions Support rescission of NCUA overdraft and NSF fee guidance Oppose collection of vendor information in NCUA Credit Union Profile Oppose changes to NCUA collection forms outside rulemaking process Support NCUA review of normal operating level and methodology Support NCUA action to permit credit union reimbursement of dependent care expenses for federal credit union official duties Oppose NCUA acting as a climate regulator Oppose NCUA rule on succession planning Oppose NCUA rule on record retention Oppose excessive NCUA requirements for supervisory committee audits Support NCUA action to reduce scope of supervisory committee examination Support NCUA recognition of digital banking in service facility definition Support clarification of NCUA member expulsion regulations Support NCUA proposed rule on increasing overdraft flexibility Support NCUA recognition of government sponsored enterprises as government agencies for loan maturity limit purposes Support NCUA adoption of floating interest rate cap Support modification of NCUA commercial loan definition Support increased flexibility in NCUA occupancy requirements Support NCUA action to clarify loan participation limits Support NCUA modification of low-income designation process Support expanding NCUA qualified charity definition Support allowing greater weighted average life for corporate credit unions financial assets Support extension of maturity limit for corporate credit union borrowing Support NCUA adopting limited retention period for operational records Support increased flexibility for advertising and notice of insured status Oppose proposed incentive-based compensation rule Support increased compliance timeline for NCUA simplification of share insurance rule Support removing reputational risk as a component of credit union examinations Support balanced implementation of debanking executive order Support increased NCUA efforts to promote credit union industry Support modernization and streamlining of NCUA operations Support NCUA supervisory flexibility for credit union shutdown assistance efforts Support NCUA action to modernize CAMELS rating system Support modernization of NCUA fidelity bond review requirements Support making CFPB subject to regular appropriations process Support increased CFPB budget transparency Support restructuring CFPB leadership to a bipartisan commission Support creation of a CFPB Inspector General Support reforms to CFPB Civil Investigative Demand process Support increasing asset thresholds for CFPB supervision of credit unions Support clarification of CFPB unfair, deceptive, or abusive acts and practices authority Support CFPB use of Section 1022 authority to exempt credit unions from certain regulations Support CFPB oversight and monitoring of nonbank entities Oppose CFPB efforts to avoid requirements of the rulemaking process Support CFPB use and disclosure of relevant data in rulemakings Support CFPB use of cost-benefit analysis in rulemaking process Support CFPB policies to promote innovation and access to credit Support CFPB coordination with NCUA on policy matters and examination scheduling Oppose mislabeling financial services fees as junk fees Oppose arbitrary limits on credit union fee income Oppose CFPB efforts to restrict information in credit reports Oppose CFPB efforts to manipulate consumer complaint data Support CFPB engaging in ongoing retrospective review of past regulations Support CFPB consumer complaint database reforms Support CFPB no-action letter program with extended timeline and increased protection of sensitive strategic information Oppose CFPB action to prohibit use of certain contractual terms and conditions Oppose expansion of consumer report and consumer reporting agency definitions under the Fair Credit Reporting Act/Regulation V Support consumer protection regulations for buy-now-pay-later loan providers Support inclusion of buy-now-pay-later loans in FHA underwriting Support CFPB use of Civil Penalty Fund for consumer financial education Support increase of Home Mortgage Disclosure Act reporting thresholds Support removal of disparate impact analysis from Regulation B and modification of discouragement standard Support credit union access to universal service fund letters of credit program Support recognition of unique credit union structure in Financial Data Transparency Act joint data standards Support federal data privacy and security standard that exempts Gramm-Leach-Bliley Act covered institutions, preempts state laws, operates on an opt-out basis, recognizes the complexity of data deletion, and does not authorize private right of action Support increased transparency for fintech bank charter applications Support Treasury development of model forms and qualified vehicle list for auto loan interest deduction Support safe harbor for credit unions related to the auto loan interest deduction Support clarification of remittance transfer tax exemptions Support inclusion of credit unions in Trump Accounts program Oppose development of a central bank digital currency Support credit union access to Federal Reserve liquidity options Support gradual expansion of Fedwire and National Settlement Service operating hours with optional participation Oppose addition of fourth same-day ACH window Support expanded flexibility for accessing the Fed discount window and intraday credit Oppose expanded eligibility for Federal Reserve master account access Oppose Regulation II debit interchange fee cap Oppose Federal Reserve proposed rule on modifying Regulation II debit interchange cap Support improvements to the Federal Reserves Debit Card Issuer Survey Oppose legislative action to impose caps or restrictions on debit or credit interchange fees Oppose legislative action to prohibit the Federal Reserve from paying interest on reserves Support Federal Reserve action to coordinate regulatory guidance on penny circulation issues and management of penny supply Support continued offering of Federal Reserve check services Oppose expansion of Electronic Fund Transfer Act/Regulation E financial institution liability Support fair distribution of Electronic Fund Transfer Act/Regulation E error resolution responsibilities Oppose Electronic Fund Transfer Act/Regulation E liability for financial institutions for consumer-authorized transactions Support clarification of funds definition under Electronic Fund Transfer Act/Regulation E Support clarification of Electronic Fund Transfer Act/Regulation E treatment of digital assets Support increased flexibility for check holds and funds availability requirements Support transition to electronic payments for government payments Support consumer education on transition to electronic payments Support clarification of information sharing safe harbor for identifying and preventing payments fraud Support greater flexibility for credit unions to decline services with clear indica of fraud or elder abuse Support parity for credit union provision of digital asset services Prevent competitive disadvantages for credit unions and market distortions related to the integration of digital assets into traditional financial products Support Treasury and NCUA action to implement regulatory framework for stablecoin issuance Support parity for credit unions related to stablecoin regulation Support NCUAs role as primary regulator of credit unions stablecoin activities Oppose treating stablecoins or digital assets as federally insured Oppose payment of interest, yield, or rewards on stablecoin holdings Support digital assets guardrails to prevent deposit outflows Support clarifying credit unions authority to provide custodial services for their members Support safeguards for rehypothecation of digital assets Support reduced government-sponsored enterprises costs for credit union mortgages Support secondary mortgage market access for credit unions Support continued role for FHFA as an independent regulator Support credit union access to Federal Home Loan Bank system Support expansion of Federal Home Loan Bank Act community financial institution definition Support Federal Home Loan Bank engagement with credit unions Oppose adoption of volume-based incentives for Federal Home Loan Banks Oppose policy changes to limit access to Federal Home Loan Bank liquidity Support Federal Home Loan Bank allocations to the Affordable Housing Program Support FinCEN implementation of the Corporate Transparency Act Support additional time to implement anti-money laundering/countering financing of terrorism program changes and publication of guidance Support increasing Currency Transaction Report and Suspicious Activity Report filing thresholds Support streamlining Currency Transaction Report and Suspicious Activity Report forms Support increased inclusion of identifiable information in Section 314(a) information requests Support consistency between NCUA and FinCEN requirements on Bank Secrecy Act compliance Support FinCEN survey to accurately measure Bank Secrecy Act compliance costs Support DOD clarification of Military Lending Act and Servicemembers Civil Relief Act requirements Support standardized disclosures and financial literacy briefings for servicemembers Support credit union access to nominal leases on military installations Oppose nominal leases for banks on military installations Oppose legislative action on the Overseas Military Banking Program Oppose inclusion of interchange or interest rate cap amendments in the National Defense Authorization Act Support federal share insurance for all credit unions acting as fiscal agents of the U.S. government Support role of Community Development Financial Institutions Fund in promoting economic growth and access to capital in underserved communities Support access to Community Development Financial Institutions Fund awards and technical assistance for credit unions Support Community Development Financial Institutions Fund bond guarantee program Support Community Development Financial Institutions Fund liquidity enhancement pilot program Support disbursement of all Community Development Financial Institution Fund appropriated award funding Oppose additional barriers to disbursement of Community Development Financial Institution Fund appropriated award funding Support timely completion of Emergency Capital Investment Program disposition agreements Oppose CFPB rulemaking on contract terms and conditions Oppose reclassification of credit header information as a consumer report Oppose reliance on single source of documentation to determine instances of identity theft or coerced debt Oppose use of interim final rule to modify personal financial data rights requirements Support modification of Section 1033 rule to allow data providers to charge fees, remove prescriptive technology standards, and establish data privacy standards and allocation of liability Support increased reporting and small business revenue threshold and elimination of discretionary data points collection in revised Section 1071 rule Support modernization of e-signature requirements Support allowing electronic or documented oral credit card applications Support increased flexibility for disclosures Support rescission of CFPB payday lending rule payment provisions Support modification of FCC revocation of consent rule Support greater flexibility for FCC fraud alert exemption Support uniform federal standards and increased federal preemption of state laws on interchange, data privacy, artificial intelligence, and elder financial abuse reporting Issues related to housing finance reform Issues related to flood insurance Issues related to privately insured credit unions Issues related to credit union capital requirements Issues related to credit union conversions Issues related to credit unions as employers Issues related to the Foreign Account Tax Compliance Act Issues related to fair lending Issues related to the Telephone Consumer Protection Act Support Credit Union Board Modernization Act (H.R. 975; S. 522) Support 1071 Repeal to Protect Small Business Lending Act (H.R. 976; S. 557) Support Making the CFPB Accountable to Small Businesses Act (H.R. 1606) Support Financial Integrity and Regulation Management Act (S. 875; H.R. 2702; Senate Amendment 3104) Support Fair Audits and Inspections for Regulators Act (H.R. 940) Support Anti-CBDC Surveillance State Act (H.R. 1919; S. 1124) Support Veterans Member Business Loan Act (H.R. 507; S. 110; Senate Amendment 3776) Support Taking Account of Bureaucrats Spending Act (H.R. 654) Support Rectifying UDAAP Act (H.R. 1652) Support Civil Investigative Demand Reform Act (H.R. 1653) Support SECURE Notarization Act (H.R. 1777; S. 1561) Support Increasing Credit Union Lending for Business Growth Act (H.R. 1791) Support Financial Reporting Threshold Modernization Act (H.R. 1799; Amendment 715 to H.R. 3838) Support Home of Your Own Act (H.R. 2064) Support Homes for Every Local Protector, Educator, and Responder Act (H.R. 2094; S. 978) Support CFPB Dual Mandate and Economic Analysis Act (H.R. 2183) Support Transparency in CFPB Cost-Benefit Analysis Act (H.R. 2331) Support CFPB-IG Reform Act (H.R. 2513) Support Homebuyers Privacy Protection Act (H.R. 2808; S. 1467) Support Financial Institution Regulatory Tailoring Enhancement Act (H.R. 3230) Support Halting Uncertain Methods and Practices in Supervision Act (H.R. 3379) Support Taking Account of Institutions with Low Operation Risk Act (H.R. 3380) Support Bureau of Consumer Financial Protection Commission Act (H.R. 3445) Support Advancing the Mentor-Protege Program for Small Financial Institutions Act (H.R. 3709) Support Expanding Access to Lending Options Act (H.R. 4167) Support CDFI Bond Guarantee Program Improvement Act (S. 1880) Support Taskforce for Recognizing and Averting Payment Scams Act (H.R. 4936; S. 2019; Senate Amendment 3257) Support Capping Excessive Awarding of SBLC Entrants Act (H.R. 2987) Support Expanding Access to Lending Options Act (H.R. 4167) Support Supervisory Modifications for Appropriate Risk-Based Testing Act (H.R. 4437) Support Stop Agency Fiat Enforcement Act (H.R. 4460) Support American Access to Banking Act (H.R. 4544) Support Protecting Access to Credit for Small Businesses Act (S. 2486) Support Business of Insurance Regulatory Reform Act (H.R. 4735; S. 2419) Support NCUA Central Liquidity Facility Enhancement Act (S. 2545, S. 3575; Senate Amendments 3722, 3834, 4384) Support CDFI Fund Transparency Act (S. 2704; Senate Amendments 3640, 3732) Support Supporting Upgraded Property Projects and Lending for Yards Act (H.R. 4568) Support Unleashing AI Innovation in Financial Services Act (H.R. 4801) Support AI Practices, Logistics, Actions, and Necessities Act (H.R. 2152) Support Streamlining Transaction Reporting and Ensuring Anti-Money Laundering Improvements for a New Era Act (S. 3017) Support NFIP Continuation Act (H.R. 5577) Support Housing for the 21st Century Act (H.R. 6644) Support Regulatory Efficiency, Verification, Itemization, and Enhanced Workflow Act (H.R. 6544) Support Community Bank Regulatory Tailoring Act (H.R. 7056) Support Close the Shadow Banking Loophole Act (S. 3734) Support American Lending Fairness Act (S. 3889; H.R. 7866) Support Community Bank Relief Act (S. 3849; H.R. 7484) Support Access to Fair Financing for Opportunity and Resilient Development Act (Senate Amendments 4354, 4394; S. 3940) Support Growing Deposit Insurance for the Future Act (H.R. 8088) Support emergency transaction account guarantee legislation (H.R. 8075) Support inclusion of guidance on penny circulation in Common Cents Act (H.R. 3074) Support parity for credit unions and prohibition on stablecoin yield in Digital Asset Market Clarity Act (H.R. 3633) Support modification of Section 705 in Renewing Opportunity in the American Dream to Housing Act (S. 2651) Support inclusion of credit union parity provisions in Main Street Capital Access Act (H.R. 6955) Oppose 10 Percent Credit Card Interest Rate Cap Act (H.R. 1944; S. 381; Senate Amendment 2239) Oppose Credit Card Competition Act (Senate Amendments 2229, 2230, 2345, 4305; S. 3623; H.R. 7035) Oppose commissary interchange fee study (Senate Amendment 3216) Oppose End the Feds Big Bank Bailout Act (S. 2113; Senate Amendment 3761) Oppose Credit Card Fairness Act (S. 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H.R. 5047: No Woke Indoctrination of Military Kids Act H.R. 515: Ensuring Military Readiness Not Discrimination Act H.R. 3944: Military Construction and Veterans Affairs, Agriculture, and Legislative Branch Appropriations Act, 2026 H.R. 4016; S. 2572: Department of Defense Appropriations Act, 2026 H.R. 5635: Veterans Healthcare Equality Act of 2025 S. 1071: National Defense Authorization Act for Fiscal Year 2026 H.R. 3838: Streamlining Procurement for Effective Execution and Delivery and National Defense Authorization Act for Fiscal Year 2026 H.R. 7238; S. 3691: Commission on Equity and Reconciliation in the Uniformed Services Act","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":6580,"prefix":null,"prefix_display":null,"first_name":"DAVID","nickname":null,"middle_name":null,"last_name":"STACY","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":138365,"prefix":"mrs","prefix_display":"MRS.","first_name":"JENNIFER","nickname":null,"middle_name":"PIKE","last_name":"BAILEY","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":145995,"prefix":null,"prefix_display":null,"first_name":"MATTHEW","nickname":null,"middle_name":null,"last_name":"ROSE","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":25,"name":"Defense, Dept of (DOD)"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":1,"name":"SENATE"},{"id":42,"name":"Veterans Affairs, Dept of (VA)"}]},{"general_issue_code":"IMM","general_issue_code_display":"Immigration","description":"Asylum for LGBTQ Immigrants Comprehensive Immigration Reform Deferred Action for Childhood Arrivals (DACA) Expedited Resettlement of LGBTQ Refugees H.R. 1589: American Dream and Promise Act of 2025 H.R. 7147, the Department of Homeland Security Appropriations Act for FY2026","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":6580,"prefix":null,"prefix_display":null,"first_name":"DAVID","nickname":null,"middle_name":null,"last_name":"STACY","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":138365,"prefix":"mrs","prefix_display":"MRS.","first_name":"JENNIFER","nickname":null,"middle_name":"PIKE","last_name":"BAILEY","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":145995,"prefix":null,"prefix_display":null,"first_name":"MATTHEW","nickname":null,"middle_name":null,"last_name":"ROSE","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":201,"name":"Homeland Security, Dept of (DHS)"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"FOR","general_issue_code_display":"Foreign Relations","description":"HIV/AIDS in PEPFAR Non-discrimination in service delivery at foreign assistance agencies LGBTQ Human Rights Issues LGBTQ+ specific sanctions Nominations State, Foreign Operations FY26 Appropriations LGBTQ+ Refugees Transparency and Reporting H.Res. 199: Condemning woke foreign aid programs. H.Con.Res. 23: Supporting the goals and ideals of International Transgender Day of Visibility. S. 280: Global Health, Empowerment and Rights Act H.R. 4245; S. 2231: GLOBE Act of 2025 S. 2180: Global Respect Act of 2025 H.R. 4779: National Security, Department of State, and Related Programs Appropriations Act, 2026 H.R. 6056; S. 3426: International Human Rights Defense Act of 2025 H.R. 6151; S. 2180: Global Respect Act","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":6580,"prefix":null,"prefix_display":null,"first_name":"DAVID","nickname":null,"middle_name":null,"last_name":"STACY","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":138365,"prefix":"mrs","prefix_display":"MRS.","first_name":"JENNIFER","nickname":null,"middle_name":"PIKE","last_name":"BAILEY","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":145995,"prefix":null,"prefix_display":null,"first_name":"MATTHEW","nickname":null,"middle_name":null,"last_name":"ROSE","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":23,"name":"Agriculture, Dept of (USDA)"},{"id":25,"name":"Defense, Dept of (DOD)"},{"id":34,"name":"Health & Human Services, Dept of (HHS)"},{"id":201,"name":"Homeland Security, Dept of (DHS)"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":37,"name":"Justice, Dept of (DOJ)"},{"id":38,"name":"Labor, Dept of (DOL)"},{"id":18,"name":"Office of Management & Budget (OMB)"},{"id":1,"name":"SENATE"},{"id":39,"name":"State, Dept of (DOS)"},{"id":41,"name":"Treasury, Dept of"},{"id":196,"name":"U.S. Agency for International Development (USAID)"},{"id":93,"name":"U.S. Trade & Development Agency (USTDA)"},{"id":12,"name":"White House Office"}]},{"general_issue_code":"EDU","general_issue_code_display":"Education","description":"Title IX Non-Discrimination for LGBTQ+ Students School Athletics School Climate Anti-Bullying School Discipline H.R. 2452: To provide that for purposes of determining compliance with title IX of the Education Amendments of 1972, locker room facilities in active use in connection with an education program or activity may be in use only by individuals of the same sex as determined solely on each individual's reproductive biology and genetics at birth. H.R. 1282: Eliminate DEI in Colleges Act H.R. 1810; S. 986: Safe Schools Improvement Act S. 1845: No Loan Forgiveness for Terrorists Act of 2025 H.R. 2617: Say No To Indoctrination Act H.R. 2616: PROTECT Kids Act H.R. 2682: STOP Bullying Act H.R. 5116; S. 2702: Empower Parents to Protect their Kids Act of 2025 S. 2251: Say No to Indoctrination Act H.R. 5486; S. 2876: Tyler Clementi Higher Education Anti-Harassment Act of 2025 H.R. 7981: To amend the Elementary and Secondary Education Act of 1965 to prohibit funds under such Act from being provided to public elementary and secondary schools that provide counseling, therapy, or guidance related to gender identity to students under 18 years of age, and for other purposes. H.R. 7661: Stop the Sexualization of Children Act H.R. 7691: Fight Book Bans Act","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":6580,"prefix":null,"prefix_display":null,"first_name":"DAVID","nickname":null,"middle_name":null,"last_name":"STACY","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":138365,"prefix":"mrs","prefix_display":"MRS.","first_name":"JENNIFER","nickname":null,"middle_name":"PIKE","last_name":"BAILEY","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":145995,"prefix":null,"prefix_display":null,"first_name":"MATTHEW","nickname":null,"middle_name":null,"last_name":"ROSE","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":32,"name":"Education, Dept of"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"HOU","general_issue_code_display":"Housing","description":"Housing Opportunities for Persons with AIDS (HOPWA) Program Appropriations H.R. 3696: Fair and Equal Housing Act of 2025 H.R. 4552; 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MCUL is advocating that Congress hold retailers to the same or similar data security standard as the financial service industry has to abide by and require that retailers notify credit unions sooner once a breach occurs. We support the introduction and passage of legislation that ensures all businesses, institutions and organizations that collect, collect, use or share personal data subject to national standards, to include language that preempts state requirements, among other things. MCUL supports modernizing the Federal Credit Union Act (FCUA). The financial service industry is rapidly changing. Advancements in technology, including high speed internet connectivity, have significantly changed our society and how financial institutions do business. Updating the FCUA has become necessary to ensure federally chartered credit unions have the powers and flexibility to be competitive and members can benefit from new technology. We are currently supporting the Veterans Member Business Loan Act (S.210/H.R. 507) that would exempt credit union business loans to veterans from the member business lending cap and we are supporting the Credit Union Board Modernization Act (S.522/H.R. 975) which would afford federal credit unions flexibility with regard to how often their boards meet. MCUL is monitoring developments for GSE/housing finance reform and will advocate to make sure any reforms reflect the significant role credit unions play in the secondary mortgage market and we will defend against anything that is potentially harmful to credit unions and their members. MCUL is calling on Congress to pass bank secrecy act/anti-money laundering reforms and provide financial institutions relief from unnecessary, duplicate and burdensome rules and increase the SAR and CTR thresholds. MCUL is urging lawmakers in the House to co-sponsor and support H.R. 1799, the Financial Reporting Threshold Modernization Act which would increase the CTR threshold from $10k to $30k and index it going forward for inflation. It would also increase the SAR threshold from $5k to $10k. MCUL is educating members of our congressional delegation on the growing interest among credit union members and credit unions in cryptocurrency. We believe Congress should explore ways to regulate the delivery of financial services using digital currencies to ensure consumers are protected in the same way if they received financial services a financial institution. We urge Congress to look for ways to enable credit unions and other financial institutions to provide digital assets, so that these services can be properly overseen by federal regulators. Finally, credit unions seek parity with other financial institutions in this area as credit unions must be able to offer digital/crypto products and services directly to their members in the same way that other institutions can to their customers. Lastly, credit unions are non-for-profit member-owned financial institutions. Credit unions' consumer-focused model is self-regulating and a principal reason why credit unions are not covered by the Community Reinvestment Act (CRA). MCUL will educate members of the delegation of the work credit unions are doing to serve low/moderate-income, diverse communities and the negative impacts of including credit unions in the CRA. We will oppose efforts that would result in credit unions of any size being included in the CRA.","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":66027,"prefix":null,"prefix_display":null,"first_name":"TODD","nickname":null,"middle_name":null,"last_name":"JORNS","suffix":null,"suffix_display":null},"covered_position":null,"new":true}],"government_entities":[{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"TAX","general_issue_code_display":"Taxation/Internal Revenue Code","description":"MCUL continues to educate members of the delegation on the importance of the credit union not-for-profit tax status to members and the benefits to non-members and how credit unions are different from other financial institutions. We oppose any efforts to change the credit union tax status/exemption in budget reconciliation legislation, including eliminating the tax exemption for \"large credit unions\" only. In addition, we continue to educate our delegation on the limited practice of credit unions purchasing bank assets and oppose any language in the budget reconciliation bill or elsewhere that would limit these purchases.","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":66027,"prefix":null,"prefix_display":null,"first_name":"TODD","nickname":null,"middle_name":null,"last_name":"JORNS","suffix":null,"suffix_display":null},"covered_position":null,"new":true}],"government_entities":[{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"BAN","general_issue_code_display":"Banking","description":"MCUL stands opposed to efforts to change the existing credit card interchange system by expanding requirements under the so-called Durbin Amendment established under the Dodd-Frank wall Street Reform and Consumer Protection Act of 2010. We have been educating our delegation on the importance of the current credit card interchange system with regard to ensuring consumer data remains secure and private and are asking our delegation to oppose any legislation of this type, including the Credit Card Competition Act. We continue to educate our congressional delegation on voluntary overdraft protection services offered by credit unions and the value our members place on these services. MCUL is opposed to legislation that would severely limit a financial institution's ability to offer these voluntary, opt-in services to our members who want access. MCUL is urging Congress to fully fund the CDFI program in FY26 and call on the Administration to release FY25 that were appropriated so awardees can utilize those dollars to carry out programs and services that assist people in need. We are also calling on Congress to improves program transparency, accountability and oversight. MCUL is supporting H.R. 3445, the Bureau of Consumer Financial Protection Commission Act, that would restructure the CFBP from a one director led agency to a 5-member commission led agency. MCUL is opposed to the 10 Percent Credit Card Interest Rate Cap Act (H.R. 1944/S.381) and is educating members of Congress on the negative impact the legislation would have on a substantial number of Americans, especially those with poor credit.","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":66027,"prefix":null,"prefix_display":null,"first_name":"TODD","nickname":null,"middle_name":null,"last_name":"JORNS","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":1,"name":"SENATE"}]}],"conviction_disclosures":[],"foreign_entities":[],"affiliated_organizations":[]},{"url":"https://lda.gov/api/v1/filings/4f1cfeb8-eeab-4d46-8b34-5fb22f6898b3/","filing_uuid":"4f1cfeb8-eeab-4d46-8b34-5fb22f6898b3","filing_type":"Q1","filing_type_display":"1st Quarter - Report","filing_year":2026,"filing_period":"first_quarter","filing_period_display":"1st Quarter (Jan 1 - Mar 31)","filing_document_url":"https://lda.gov/filings/public/filing/4f1cfeb8-eeab-4d46-8b34-5fb22f6898b3/print/","filing_document_content_type":"text/html","income":null,"expenses":"387651.00","expenses_method":"C","expenses_method_display":"C","posted_by_name":"Kevin George","dt_posted":"2026-04-16T13:32:11-04:00","termination_date":null,"registrant_country":"United States of America","registrant_ppb_country":"United States of America","registrant_address_1":"1776 I St NW","registrant_address_2":"Ste 200","registrant_different_address":true,"registrant_city":"Washington","registrant_state":"DC","registrant_zip":"20006","registrant":{"id":401103239,"url":"https://lda.gov/api/v1/registrants/401103239/","house_registrant_id":42535,"name":"STRUCTURED FINANCE ASSOCIATION","description":"Financial services trade assn. focused on structured finance & securitization issues.","address_1":"1776 I St NW","address_2":"Ste 200","address_3":null,"address_4":null,"city":"Washington","state":"DC","state_display":"District of Columbia","zip":"20006","country":"US","country_display":"United States of America","ppb_country":"US","ppb_country_display":"United States of America","contact_name":"KEVIN GEORGE","contact_telephone":"+1 507-995-1690","dt_updated":"2026-10-15T16:14:55.706882-04:00"},"client":{"id":198279,"url":"https://lda.gov/api/v1/clients/198279/","client_id":12,"name":"STRUCTURED FINANCE ASSOCIATION","general_description":null,"client_government_entity":false,"client_self_select":true,"state":"DC","state_display":"District of Columbia","country":"US","country_display":"United States of America","ppb_state":"DC","ppb_state_display":"District of Columbia","ppb_country":"US","ppb_country_display":"United States of America","effective_date":"2014-03-10"},"lobbying_activities":[{"general_issue_code":"FIN","general_issue_code_display":"Financial Institutions/Investments/Securities","description":"1. Basel Capital and Liquidity Treatment for asset-backed securities - General issues concerning the appropriate treatment for bank investment in asset-backed securities under final Basel III capital and liquidity rules (includes the Liquidity Coverage Ratio, The Fundamental Review of the Trading Book, efforts to create \"Simple, Transparent and Comparable\" (STC) securitizations, STC treatment for short-term securitizations, and capital treatment of consolidated SPEs when risk transfer occurs). 2. Regulation AB II - Issues concerning disclosure requirements (current and potential) under the SEC's regulation AB II for all ABS asset classes, specifically auto, credit card, equipment lease and student loans. 3. General Dodd-Frank Implementation and Reform Efforts - Issues concerning the implementation of DFA final rules, including risk retention, the Liquidity Coverage Ratio (LCR), and uncleared swap margin rules; issues related to risk retention provisions, the Volcker Rule (discussed SFA's recommended changes with staff at SEC, Federal Reserve Board, FDIC and OCC), arbitration clauses, lead regulator concept, and \"valid when made\" loan provisions; reform proposals as they relate to securitization and capital markets generally; the implementation of the Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018, specifically provisions potentially related to securitization. 4. SFA is a member of the Alternative Reference Rates Committee (ARRC) at the Federal Reserve Bank of New York working to determine best path for transition away from LIBOR (in 2021, the U.K.s Financial Conduct Authority will stop compelling banks to report LIBOR). SFA co-chairs the ARRCs Securitization Working Group which meets regularly with the goal of producing concrete recommendations on how best to effect the transition. 5. Advocacy related to industry concerns regarding the Bureaus proposed consent judgment in the case of Consumer Financial Protection Bureau v. National Collegiate Master Student Loan Trusts. This case has broad implications for the securitization market as the consent order could alter the parties settled contractual rights and obligations in these transactions. 6. Employee Retirement Income Security Act of 1974 (ERISA) - Issues relating to the interpretation and implementation of amendments and exemptions to ERISA as they relate to structured finance; issues related to ERISA disclosures provided in securitization offering documents. 7. Trust Indenture Act of 1939 (TIA) - Issues relating to a potential conflict with a provision of the Trust Indenture Act - allowing for a clarification to be limited to the LIBOR transition event and eliminating the potential of setting an unintended precedent. 8. True Lender - Issues relating to the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J. Res. 15. 9. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 10. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 11. SEC Rule 15c2-11 - Advocacy related to concerns regarding the rule's public disclosure requirements, and a push for delayed implementation or complete rule reversal. 12. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":69139,"prefix":null,"prefix_display":null,"first_name":"LESLIE","nickname":null,"middle_name":"J.","last_name":"SACK","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":148232,"prefix":null,"prefix_display":null,"first_name":"DANIEL","nickname":null,"middle_name":null,"last_name":"GRATTAN","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":153392,"prefix":null,"prefix_display":null,"first_name":"KEVIN","nickname":null,"middle_name":null,"last_name":"GEORGE","suffix":null,"suffix_display":null},"covered_position":"Legislative Director, Senior Economic Policy Advisor, Rep. Stephen Lynch; Legislative Aide, Sen. Heidi Heitkamp; Legislative Fellow, Rep. 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Review and provide feedback on draft bipartisan bill to reform Fannie Mae and Freddie Mac. 2. General Housing Finance Issues - Issues concerning FHFA's efforts to implement both a uniform mortgage backed security (UMBS) and common securitization platform (CSP), including increased risk sharing, transparency, and industry participation. Providing commentary and analysis on the FHFA's proposed capital framework for the GSEs. 3. Private-Label Securities (PLS) - General issues related to support for industry agreed-upon solutions arrived at in its RMBS 3.0 project for inclusion as part of any new structure for the return of private-label mortgage-backed securities; issues related to the facilitation of deal agent initiatives (PLS initiatives). 4. Support of a free-market, competition-based approach to the GSE's use of alternative credit models. 5. TILA-RESPA Integrated Disclosure Rule (TRID) - General issues concerning clarity and implementation of CFPB rules. 6. CFPB Regulatory Guidance - Proposals to reform the process by which the CFPB introduces and uses guidance in conjunction with regulation. 7. ATR/QM - General issues concerning loan origination and GSE underwriting standards. 8. False Claims Act - Advocating for the establishment of HUD guidelines to avoid/deter misuse of the FCA by the Dept. of Justice, including lobbying and advocacy around proposed legislative fixes to the FCA. 9. Regulation AB II - Issues concerning disclosure requirements (current and potential) under the SEC's regulation AB II as it relates to RMBS issuance offerings. 10. Issues related to the Taxpayer Protection Act. 11. Credit Risk Transfer (CRT) - Issues related to the treatment of residential mortgage loans in forbearance under Section 4022 of the CARES Act as a delinquent loan under its fixed severity CRT bonds issued in 2013 and 2014 and concerns the about CRT programs of the GSEs as it relates to the FHFA's Enterprise Capital Rule re-proposal. 12. Enterprise Capital Rule Re-proposal - Issues related to the FHFA's re-proposed Enterprise Capital Rule and its potential impact on the broader system of housing services in the United States. 13. S. 98 - The Neighborhood Homes Investment Act - The Neighborhood Homes Investment Act (NHIA) creates a federal tax credit that covers the cost between building or renovating a home in these areas and the price at which they can be sold. The NHIA would also help existing homeowners in these neighborhoods to renovate and stay in their homes.","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":69139,"prefix":null,"prefix_display":null,"first_name":"LESLIE","nickname":null,"middle_name":"J.","last_name":"SACK","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":148232,"prefix":null,"prefix_display":null,"first_name":"DANIEL","nickname":null,"middle_name":null,"last_name":"GRATTAN","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":153392,"prefix":null,"prefix_display":null,"first_name":"KEVIN","nickname":null,"middle_name":null,"last_name":"GEORGE","suffix":null,"suffix_display":null},"covered_position":"Legislative Director, Senior Economic Policy Advisor, Rep. Stephen Lynch; Legislative Aide, Sen. Heidi Heitkamp; Legislative Fellow, Rep. 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Issues/proposals in support of equitable liquidity and capital treatment for securitizations held on bank balance sheets and bank trading books, specifically, Basel Capital and Liquidity Rules (Liquidity Coverage Ratio, the Net Stable Funding Ratio, Corporate Transparency Act, the Fundamental Review of the Trading Book and STC capital treatment for short-term securitizations, securitization surcharge/p-factor). 3. Federal Reserves Control Proposal - Issues relating to the Feds proposed rule making on regulations relating to controlling influence over another company under the Bank Holding Company Act (BHC Act) and the Home Owners Loan Act (HOLA), that would formalize Reg Y and Reg LL frameworks for making controlling influence determinations. Specifically, SFA requests that asset-backed commercial paper (ABCP)conduits be exempted from any accounting consolidation presumption. 4. True Lender - Issues relating to repealing the Office of the Comptroller of the Currency rule issued in October 2020 that eliminates any ambiguity to when a bank is considered the true lender when extending a loan, including in the context of a bank and third-party partnership, including S.J.Res. 15. 5. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 6. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022. 7. SEC Conflicts of Interest Rule - Advocacy related to concerns regarding the rule's requirements and a push for modifications to the rule.","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":69139,"prefix":null,"prefix_display":null,"first_name":"LESLIE","nickname":null,"middle_name":"J.","last_name":"SACK","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":148232,"prefix":null,"prefix_display":null,"first_name":"DANIEL","nickname":null,"middle_name":null,"last_name":"GRATTAN","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":153392,"prefix":null,"prefix_display":null,"first_name":"KEVIN","nickname":null,"middle_name":null,"last_name":"GEORGE","suffix":null,"suffix_display":null},"covered_position":"Legislative Director, Senior Economic Policy Advisor, Rep. Stephen Lynch; Legislative Aide, Sen. Heidi Heitkamp; Legislative Fellow, Rep. 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S. 98 - The Neighborhood Homes Investment Act - The Neighborhood Homes Investment Act (NHIA) creates a federal tax credit that covers the cost between building or renovating a home in these areas and the price at which they can be sold. The NHIA would also help existing homeowners in these neighborhoods to renovate and stay in their homes. 4. Section 1062 (Certain Sales Between Grantor Trust and Deemed Owner) of the Amendment in the Nature of a Substitute to the Build Back Better Act (H.R. 5376) which would treat certain grantor trusts as separate from their owners for certain purposes. 5. LIBOR Transition - Issues related to H.R. 4616, the Adjustable Interest Rate (LIBOR) Act of 2021 and the Consolidated Appropriations Act, 2022.","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":69139,"prefix":null,"prefix_display":null,"first_name":"LESLIE","nickname":null,"middle_name":"J.","last_name":"SACK","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":148232,"prefix":null,"prefix_display":null,"first_name":"DANIEL","nickname":null,"middle_name":null,"last_name":"GRATTAN","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":153392,"prefix":null,"prefix_display":null,"first_name":"KEVIN","nickname":null,"middle_name":null,"last_name":"GEORGE","suffix":null,"suffix_display":null},"covered_position":"Legislative Director, Senior Economic Policy Advisor, Rep. Stephen Lynch; Legislative Aide, Sen. Heidi Heitkamp; Legislative Fellow, Rep. 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S.931: Complete Care Act: Integrating Behavioral health care into primary care H.R. 1906:Rural Wellness Act: Grants for telemedicine to provide Access to care in rural communities S. 779/H.R. 1735: EARLY Minds Act allows States to use some Mental Health Block Grant funds towards prevention and early intervention activities. H.R. 1902: HERO Act allows for the collection of data on first responder suicides to better identify and treat PTSD and combat suicide. S. 665: Fatal Overdose Reduction Act of 2025 creates hubs to treat substance use disorders. H.R. 1305: Improving Measurements for Loneliness and Isolation Act of 2025 creates a working group to better understand and define loneliness and isolation. S. 600: Supporting Adopted Children and Families Act enhances pre and post adoption services. S. 454: Gambling Addiction Recovery, Investment, and Treatment Act creates grants for state to address gambling addiction. S. 266/H.R. 929: Dr. Lorna Breen Health Care Provider Protection Reauthorization Act continues education and awareness for mental health services. H.R. 2483: SUPPORT for Patients and Communities Reauthorization Act of 2025 extends and expands grants for serious mental illness and substance use disorder. Support for the inclusion of those with lived experience on the Make America Health Again (MAHA) Commission Support for staffing levels as of 1.1.25 at HHS and SAMHSA Support for Maternal Mental Health programs and funding Support for ending Medicare's 190-day lifetime limit on inpatient psychiatric care -- H.R. 1141: Gambling Addiction Recovery, Investment, and Treatment Act authorizes grants to states and research funding to address gambling addiction. H.R. 2044: Suicide Prevention Assistance Act establishes grants for primary care offices to provide self-harm and suicide prevention services. H.R. 2223: Building Capacity for Care Act provides financial support for developing mental health and substance use disorder treatment facilities. H.R. 2305: Corrections Officer Blake Schwarz Suicide Prevention Act of 2025 establishes a grant program to fund mental health screenings and referrals for corrections officer. H.R. 2587/S.1266: Youth Mental Health Research Act establishes a collaborative research initiative within the NIH to improve youth mental health. H.R. 2630: Youth Suicide Prevention Research Act expands research focus areas on childhood suicide to include adverse childhood experiences and toxic stress. H.R. 2904: Pursuing Equity in Mental Health Act authorizes federal grants for culturally competent research, outreach, provider training, and priority support for programs. H.R. 2936: Addressing Boarding and Crowding in the Emergency Department Act allows grants for tracking hospital bed capacity and introduces pilot programs for emergency care improvements. H.R. 2957: STRONG Support for Children Act of 2025 establishes programs aimed at preventing and mitigating childhood trauma through data analysis and strategy implementation. H.R. 3103: Health Share Transparency Act of 2025 requires health care sharing ministries to disclose financial and operational information to federal agencies and enrollees. H.R. 3130: FACTS Act establishes education and public health partnerships to prevent synthetic opioid misuse among youth. H.R. 3262: NURSE Act creates grants to increase school nurses in under-resourced schools. H.R. 3266: Mental Health Infrastructure Improvement Act of 2025 provides loans to expand and improve pediatric and adult mental health and substance use disorder treatment facilities. H.R. 3420: Words Matter Act of 2025 replacing outdated and stigmatizing terms related to intellectual disabilities with more respectful language. H.R. 3505: Barriers to Suicide Act of 2025 creates a grant program to install nets and barriers on infrastructures like bridges and railroads. H.R. 3520: STAND Against Emerging Opioids Act schedules tianeptine and its analogues as Schedule III controlled substances. H.R. 3601: National ACERT Grant Program Authorization Act establishes a new grant program focused on addressing adverse childhood experiences related to trauma exposure. H.R. 3689: TREAT Youth Act reauthorizes and increases funding for youth substance use prevention and recovery initiatives under the SUPPORT for Patients and Communities Act. H.R. 3743: Supporting Healthy Mothers and Infants Act of 2025 modernizes language for substance use disorder and expands nutrition education and outreach. S. 1056: Home-Based Telemental Health Care Act of 2025 establishes a grant program to improve mental health and substance use services for rural populations through telemental health care. S. 1062: Suicide Prevention Act establishes programs to enhance surveillance of self-harm and provide suicide prevention services in hospital emergency departments. S. 1074: Agricultural Access to Substance Use Disorder Treatment and Mental Health Care Act of 2025 requires a study on the accessibility of mental health and substance use disorder services for farmers and ranchers. S. 1261: CONNECT for Health Act of 2025 seeks to expand telehealth access by removing geographic restrictions. S. 1329/H.R. 2741: PEER Support Act supports and professionalizes peer support specialists and establishes an Office of Recovery. S. 139: FASD Respect Act reauthorize and extend the Fetal Alcohol Spectrum Disorders (FASD) Prevention and Services program. S. 1448: Pursuing Equity in Mental Health Act seeks to improve mental health services and reduce disparities for racial and ethnic minority youth through increased funding, research, and education initiatives. S. 1663/H.R. 3243: Therapeutic Fraud Prevention Act of 2025 prohibits commercial conversion therapy. S. 1673/H.R. 3260: Mental Health Improvement Act extends the authorization period for mental and behavioral health education and training grants. S. 1689/ H.R. 3316: Stop Mental Health Stigma in Our Communities Act of 2025 mandates the development of a national outreach and education strategy tailored to the cultural and linguistic needs of AANHPI populations. S. 1878: ATTAIN Mental Health Act creates an online dashboard to centralize public access to information about federal and state grants for mental health and substance use disorder programs. S. 473: SENIOR Act address loneliness among older adults by requiring screenings, coordinating services, and preparing a report on loneliness. S. 931/H.R. 2509: COMPLETE Care Act incentivizes behavioral health integration with primary care through increased payments and technical assistance. S.Res. 208: A resolution supporting the designation of May 10, 2025, as \"National Asian American, Native Hawaiian, and Pacific Islander Mental Health Day.\" S.Res. 249/H.Res. 441: A resolution expressing support for the designation of May 2025 as \"Mental Health Awareness Month.\" H.R. 3305. Barriers to Suicide Act: Creates a grant program to provide suicide barriers on bridges and other structures H.Res 542/S. 332: Expressing support for the designation of the month of June 2025 as National Post-traumatic stress Awareness Month and June 27, 2025 as National Post-traumatic Stress Awareness Day H.Res 671: Prioritizing Mental Health to the Same Degree as Physical Health to address the epidemics of suicide and drug overdose in the United States H.Res 697/ S. Res 385: Recognizing Suicide as a serious public health problem and supporting September as National Suicide Prevention Month and September 10 as World Suicide Prevention Day H.Res 764: Recognizing the continuing disparities in Black youth mental health and access to care H.R. 4400/S. 2282: Farmers First Act: reauthorizes and expands funding of the Farm Ranch Suicide Prevention Act. HR 4723/ S.2446: Mental Health For Latinos Act: Directs the development of a culturally tailored mental health outreach and education strategy for Hispanic and Latino Populations. S. 2556: Protecting Health Care and Lowering Costs Act: repeals recent health law changes, permanently expands ACA Tax Credits beyond 400% FPL, and sets a new sliding scale for premium contributions H.Res 684: A resolution expressing support for the designation of September 9, 2025, as National Firearms Suicide Prevention Day HR 5509/S 2903: The Safe Step Act: Creates a clear process to appeal step therapy process S.2826/H.R. 5434:The 988 LGBTQ+ Youth Access Act of 2025: Mandates that at least 9% of suicide prevention hotline funding be reserved for specialized services supporting LGBTQ + youth H.R. 1492: To Amend title XI of the Social Security Act to equalize the negotiation period between small molecule and biologic candidates under the Drug Price Negotiation Program H.R. 2085: The Mental Health Research Accelerator Act: establishes programs to speed up mental health research and innovations H.R. 3419: To Amend the Public Health Service Act to reauthorize the telehealth network and telehealth resource center grant program H.R. 4805: WINGS ACT: Requires a report on the long-term brain and mental health effects of military aviation. H.R. 5306: Gun Suicide Prevention Act of 2025: requires all firearms sold in the United States to display the suicide prevention lifeline label H.R. 5733: Community Mental Wellness Worker Training Act: establishes a grant program to train and certify community mental wellness workers H.R. 5859: Behavioral Health Crisis Care Centers Act: establishes a grant program to fund comprehensive, one stop crisis facilities H.R. 5861: Legacy Act of 2025 mandates a study on creating a secure, national system for storing and retrieving last wish documents. H.R. 6226 Latino Youth Mental Health Empowerment Act: Establish a Mental Health awareness campaign focused on Latino youth. H.R. 6817 To establish a home-based telemental health care grant program to increase mental health and substance use services for individuals in fishing, farming and forestry occupations H.Res. 792 Declaring a need for increased investment in youth mental Health and recognizing youth mental health day and youth suicide prevention day. S.2005 IDeA Reauthorization Act: Strengthens the NIH's Institutional Development Award Program S.2131/H.R. 5828 Dad's Matter Act: Requires a federal public awareness campaign and state guidance to promote fatherhood. S.2336: Halting the Epidemic of Addiction and Loss Act: Update grant program regulation and guidance to include all FDA opioid reversal agents, not just Naloxone S. 2825/H.R.5417 Health Access Innovation Act 2025: grant program to support faith and community-based organizations in addressing health inequities and chronic disease. S.3199 988 Lifeline Location Improvement Act: creates an advisory committee to study and recommend a solution for transmitting geolocation information with 988 calls. S. 3076 Nitazene Control Act: permanently classifies all nitazene opioids as schedule 1 Support for improving integrated care for those with Tardive Dyskinesia H.R. 6249: Addressing Addiction After Disasters Act expands federal disaster relief to include SUD and AUD services alongside mental health support. H.R. 6283: FOSTER Act expand opioid response grants and defines and supports kinship caregivers. H.R. 6396: Kid PROOF Act of 2025 expands grant eligibility and funding to support suicide and overdose prevention among youth. H.R. 6630: Expanding Mental Health Access for Cyber Command Personnel Act requires security-cleared behavioral health professionals to be assigned to Cyber Command locations. H.R. 6679: Tech Wellness for Young Men Act requires a study on the mental, social, and developmental impacts of screen addiction among young men. H.R. 6680: Tech Wellness for Men Act study on the economic, mental health, and social impacts of screen addiction among adult men. H.R. 6940: Hope Heals Act of 2026 requires an assessment amount Executive departments to enhance mental health. H.R. 7030: Securing Facilities for Mental Health Services Act expands access to federal mortgage insurance for all licensed hospitals, including mental health facilities. H.R. 7602: State of Men's Health Act requires a study on men's health disparities and establishes an Office of Men's Health. H.R. 8124: STOP Suicide Act creates a grant program to support evidence-based stabilization services for individuals with serious suicidal thoughts. H.R. 8149: Agricultural Access to Addiction and Mental Health Care Act mandates a study on improving access to addiction and mental health care for farmers and ranchers. H.R. 8160: Premenstrual Dysphoric Disorder Awareness and Research Act of 2026 expand research, raise awareness, improve provider education, and increase access to care for PMDD. H.R.8122: 9-8-8 Connect Act allocates $30 million for crisis center follow-up services. S. 3230: Family Caregiver Peer Support Act creates grants to expand in-person and virtual peer support programs for family caregivers. S. 3271: In-Home CARE Act authorizes grants to support family caregivers through home visiting programs. S. 3402: Ensuring Excellence in Mental Health Act expands and standardizes community behavioral health clinic services S. 3431: Improving Measurements for Loneliness and Isolation Act of 2025 establishes a working group to standardize how loneliness and isolation are defined and measured. S. 3461: RISE from Trauma Act authorizes expands and builds trauma-informed systems for youth and families affected by trauma, violence, and substance use. S. 3714: Family-to-Family Reauthorization Act of 2026 extends and specifies funding for family-to-family health information centers. S. 3840/H.R. 7496: Health Investment Zones Act of 2026 creates Health Investment Zones for incentives, grants, and support to reduce health disparities. S. 921: Tyler's Law requires a federal study and subsequent guidance on whether hospital emergency departments should routinely test for fentanyl in overdose cases. H.R. 7875: Providing Opportunities for Individuals in Need of Treatment and Support (POINTS) Act of 2026 expands prevention, treatment, and recovery services for individuals experiencing gambling addiction. S. 4001/H.R. 7828: Supplemental Security Income Restoration Act of 2026 modernizes SSI eligibility and benefit rules.","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":139015,"prefix":"ms","prefix_display":"MS.","first_name":"HANNAH","nickname":null,"middle_name":null,"last_name":"WESOLOWSKI","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":141549,"prefix":"mr","prefix_display":"MR.","first_name":"MICHAEL","nickname":null,"middle_name":"MATTHEW","last_name":"LINSKEY","suffix":null,"suffix_display":null},"covered_position":"Legislative Correspondent for Debbie Wassermann Schultz 4/2005-10/2005","new":false},{"lobbyist":{"id":149684,"prefix":null,"prefix_display":null,"first_name":"JOANNA","nickname":null,"middle_name":null,"last_name":"ROSEN","suffix":null,"suffix_display":null},"covered_position":null,"new":true}],"government_entities":[{"id":136,"name":"Centers For Medicare and Medicaid Services (CMS)"},{"id":53,"name":"Federal Communications Commission (FCC)"},{"id":34,"name":"Health & Human Services, Dept of (HHS)"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":37,"name":"Justice, Dept of (DOJ)"},{"id":9,"name":"President of the U.S."},{"id":1,"name":"SENATE"},{"id":141,"name":"Substance Abuse & Mental Health Services Administration (SAMHSA)"}]},{"general_issue_code":"BUD","general_issue_code_display":"Budget/Appropriations","description":"Appropriations requests for Commerce, Justice, Science, and Related Agencies for FY 2027 Appropriations requests for Department of Housing and Urban Development - funding for Housing programs for those with SUD and/or SMI for FY 2027 Appropriations requests for Department of Labor, Health and Human Services, and Education and Related Agencies for FY 2027","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":139015,"prefix":"ms","prefix_display":"MS.","first_name":"HANNAH","nickname":null,"middle_name":null,"last_name":"WESOLOWSKI","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":141549,"prefix":"mr","prefix_display":"MR.","first_name":"MICHAEL","nickname":null,"middle_name":"MATTHEW","last_name":"LINSKEY","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":149684,"prefix":null,"prefix_display":null,"first_name":"JOANNA","nickname":null,"middle_name":null,"last_name":"ROSEN","suffix":null,"suffix_display":null},"covered_position":null,"new":true}],"government_entities":[{"id":157,"name":"Bureau of Justice Assistance"},{"id":34,"name":"Health & Human Services, Dept of (HHS)"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":35,"name":"Housing & Urban Development, Dept of (HUD)"},{"id":37,"name":"Justice, Dept of (DOJ)"},{"id":243,"name":"Natl Institute of Mental Health (NIMH)"},{"id":139,"name":"Natl Institutes of Health (NIH)"},{"id":9,"name":"President of the U.S."},{"id":1,"name":"SENATE"},{"id":141,"name":"Substance Abuse & Mental Health Services Administration (SAMHSA)"},{"id":12,"name":"White House Office"}]},{"general_issue_code":"TEC","general_issue_code_display":"Telecommunications","description":"H.R. 912: 9-8-8 Lifeline Cybersecurity Responsibility Act strengthens the cybersecurity protocols for the Lifeline. S. 414: ADS for Mental Health Services Act requires social media sites to report their public service ads. Ensuring the proper routing of 988 lifeline calls, texts, and chats -- H.R. 3757: Pride In Mental Health Act of 2025 establishes a grant program to enhance mental health services, protections, and data collection for LGBTQ+ youth. S. 1007: 9-8-8 Lifeline Cybersecurity Responsibility Act mandating rapid reporting of vulnerabilities and incidents. S. 1611: Youth Substance Use Prevention and Awareness Act promotes youth substance use prevention through expanded public service announcement campaigns. S. 1797: Expanding Seniors Access to Mental Health Services Act: Expands Medicare coverage and reimbursement for clinical social worker mental health services H.R. 5045: Health AI Act establishes a grant program to fund research on generative AI in health care. S. 1748: Kids Online Safety Act: requires online platforms used by minors to implement safety, privacy, and parental controls. S. 3199: 988 Lifeline Location Improvement Act creates an advisory committee to study and recommend solutions for transmitting geolocation information with 988.","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":141549,"prefix":"mr","prefix_display":"MR.","first_name":"MICHAEL","nickname":null,"middle_name":"MATTHEW","last_name":"LINSKEY","suffix":null,"suffix_display":null},"covered_position":"Legislative Correspondent Debbie Wasserman Schultz 4/2005-10/2005","new":false},{"lobbyist":{"id":139015,"prefix":"ms","prefix_display":"MS.","first_name":"HANNAH","nickname":null,"middle_name":null,"last_name":"WESOLOWSKI","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":149684,"prefix":null,"prefix_display":null,"first_name":"JOANNA","nickname":null,"middle_name":null,"last_name":"ROSEN","suffix":null,"suffix_display":null},"covered_position":null,"new":true}],"government_entities":[{"id":53,"name":"Federal Communications Commission (FCC)"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"TAX","general_issue_code_display":"Taxation/Internal Revenue Code","description":"H.R. 169: Prevent Family Fire Act provides a tax credit for retailers to incentivize the sale of safe storage devices for firearms. S. 46/H.R. 247: Health Care Affordability Act of 2025 expands access to tax credits by eliminating income caps and adjusting premium percentages. -- S. 1676/ HR 3308: RETAIN Act introduces a refundable tax credit to retain educators and school leaders in high-need areas S. 925/H.R. 2036: Credit for Caring Act of 2025 creates a tax credit for working family caregivers. H.R. 1582: Volunteer Driver Tax Appreciation Act of 2025: increase the charitable mileage rate to match the business travel for certain charitable activities. HR 5145: Bipartisan Premium Tax Credit Extension Act, extends enhances premium tax credits and expanded eligibility for health insurance subsides through 2026","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":141549,"prefix":"mr","prefix_display":"MR.","first_name":"MICHAEL","nickname":null,"middle_name":"MATTHEW","last_name":"LINSKEY","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":139015,"prefix":"ms","prefix_display":"MS.","first_name":"HANNAH","nickname":null,"middle_name":null,"last_name":"WESOLOWSKI","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":149684,"prefix":null,"prefix_display":null,"first_name":"JOANNA","nickname":null,"middle_name":null,"last_name":"ROSEN","suffix":null,"suffix_display":null},"covered_position":null,"new":true}],"government_entities":[{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"LAW","general_issue_code_display":"Law Enforcement/Crime/Criminal Justice","description":"H.R. 1510/S.1720: Due Process Continuity of Care Act extends Medicaid to those in custody pending charges H.R. 1392: Improving Mental Healthcare in the Re-Entry System Act of 2025 creates grants for mental health screenings and referrals. Support for expanding reentry services for those leaving or about to leave incarceration, including the use of 1115 waivers -- H.R. 2502: Law Enforcement Training for Mental Health Crisis Response Act of 2025 funds behavioral health crisis response training for law enforcement and corrections officers. H.R. 2586: Reentry Act of 2025 allows Medicaid coverage for inmates 30 days before their release. H.R. 2879: Prison Staffing Reform Act of 2025 requires a comprehensive review and strategic plan to address understaffing in the Bureau of Prisons. H.R. 3312: SERVICE Act of 2025 establishes a pilot program to create veterans response teams within law enforcement agencies. H.R. 3372: Law Enforcement Scenario-Based Training for Safety and De-Escalation Act of 2025 establishes a scenario-based training curriculum for law enforcement. H.R. 3621: Public Safety and Mental Health Reporting Act mandates annual federal data collection and public reporting on law enforcement interactions with people with mental illness. H.R. 3658: 911 Community Crisis Responders Act of 2025 establishes a federal grant program to support unarmed, community-based crisis response teams for nonviolent 911 calls. S. 1843: Second Chance Reauthorization Act of 2025 reauthorizes and expands funding for reentry, substance abuse treatment, education, and support programs for formerly incarcerated individuals. S. 1897: A bill to amend the Omnibus Crime Control and Safe Streets Act of 1968 to establish the Adverse Childhood Experiences Response Team grant program, and for other purposes. S. 768: Invest to Protect Act of 2025 establishes a grant program to support local law enforcement agencies with training, mental health resources, and recruitment. S. 825: Fighting Post-Traumatic Stress Disorder Act of 2025 creates a program for providing PTSD treatment to public safety officers. S. 2248: Juvenile Justice and Delinquency Prevention Reauthorization Act reauthorize key delinquency prevention programs and bolster federal protections for incarcerated minors. H.R. 4024: Filling Public Safety Vacancies Act provides a boost to the federal grant program that provides funding to departments for recruitment and hiring. S.2532 Safe Response Act expands and updates first responder training programs H.R. 5725: Mental Health Crisis Response Act establishes a grant program to help implement health centered alternation to law enforcement for mental health emergencies H.R. 6002 Supporting Blue Envelope Program Act: Establish a grant program to support Blue Envelope programs for Autism Awareness S.2532 Safe Response Act expands and updates first responder training programs to address a wider range of drug related emergencies and increases funding. H.R. 6548: DHS Suicide Prevention and Resiliency for Law Enforcement Act creates a mental health and suicide prevention program for DHS law enforcement personnel. H.R. 7309: Reentry Resource Guide Act of 2026 creates a pilot program to help states develop digital guides connecting formerly incarcerated individuals with essential reentry resources. H.R. 7447: Community Risk Training and Response Act of 2026 establishes a grants for risk protection orders and crisis intervention programs.","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":141549,"prefix":"mr","prefix_display":"MR.","first_name":"MICHAEL","nickname":null,"middle_name":"MATTHEW","last_name":"LINSKEY","suffix":null,"suffix_display":null},"covered_position":"Legislative Correspondent for Debbie Wassermann Schultz 4/2005-10/2005","new":false},{"lobbyist":{"id":139015,"prefix":"ms","prefix_display":"MS.","first_name":"HANNAH","nickname":null,"middle_name":null,"last_name":"WESOLOWSKI","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":149684,"prefix":null,"prefix_display":null,"first_name":"JOANNA","nickname":null,"middle_name":null,"last_name":"ROSEN","suffix":null,"suffix_display":null},"covered_position":null,"new":true}],"government_entities":[{"id":157,"name":"Bureau of Justice Assistance"},{"id":34,"name":"Health & Human Services, Dept of (HHS)"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":37,"name":"Justice, Dept of (DOJ)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"EDU","general_issue_code_display":"Education","description":"H.R. 1448: PEER Mental Health Act of 2025 authorizes grants for peer mental health first aid training in schools, with a focus on rural areas. S. 906: Peer to Peer Mental Health Support Act creates a pilot program for mental health peer support activities in schools. H.R. 1649: Expanding Student Access to Mental Health Services Act enhances student mental health and telehealth services. -- H.R. 3567: Put School Counselors Where Theyre Needed Act creates a federally funded demonstration project to provide additional school counselors in low-graduation-rate Title I secondary schools. H.R. 3655: STAR Plus Scholarship Act creates a federally funded scholarship program to increase and diversify the behavioral and mental health workforce in shortage areas. S. 1895/H.R. 3534: Mental Health in Schools Excellence Program Act of 2025 creates a federal matching grant program to help graduate students afford degrees in school-based mental health fields. S. 1924/H.R. 3624: Improving Mental Health Access for Students Act requires colleges and universities to provide suicide prevention contact information on student ID cards. H.R. 3939: Respond, Innovate, Support, and Empower (RISE) Act allows college students to use previous documentation as proof of disability when seeking accommodations in their courses. H.R. 4120: Supporting the Mental Health of Educators and Staff Act establishes funding, programs, and reporting requirements to improve mental health and resiliency among education professionals and school staff. H.R. 5557: Mental Health Services for Students Act of 2025: enhances and extends school-based mental health services for students. H.R. 4186: Connecting Students with Mental Health Services Act: Establishes a grant program to expand telehealth services for school children H.R. 5357: College Students Continuation of Mental Health Care Act: Allows College Mental Health providers to offer services across state lines H.R. 5482: Prevent Youth Suicide Act: Evidence-based suicide prevention programs for students H.R. 5553: CTE Student Mental Health and Wellness Act: expands eligibility for federal mental health and substance use disorder grants H.R. 6133: Increasing Access to Mental Health in Schools Act: Establishes a grant and loan repayment program for school-based mental health providers H.R. 6672: Mental Health Professionals Workforce Shortage Act: Creates a federal loan repayment program for certain mental health professionals S942/H.R. 2028: Redi Act: Interest free deferment on student loans for borrowers in medical or dental internships or residency programs H.R. 7019: Campus Prevention and Recovery Services for Students Act of 2026 expands campus alcohol and substance misuse prevention programs. H.R. 7497: Supporting Trauma-Informed Education Practices Act of 2026 expand evidence-based trauma support and mental health services for children and youth in schools. H.R. 7787: Mental Health Workforce Act creates a loan deferment and forgiveness program for mental health professionals. S. 3448/H.R. 6617: Keeping All Students Safe Act prohibits seclusion and restricts the use of restraint in federally funded educational settings. S. 4061/H.R. 7092: RAYS Act requires K-12 schools to provide mental health and suicide prevention contact information on student IDs. S. 3783/H.R. 7394: Mental Health Career Promotion Act establishes a grant program to promote mental and behavioral health careers.","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":141549,"prefix":"mr","prefix_display":"MR.","first_name":"MICHAEL","nickname":null,"middle_name":"MATTHEW","last_name":"LINSKEY","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":139015,"prefix":"ms","prefix_display":"MS.","first_name":"HANNAH","nickname":null,"middle_name":null,"last_name":"WESOLOWSKI","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":149684,"prefix":null,"prefix_display":null,"first_name":"JOANNA","nickname":null,"middle_name":null,"last_name":"ROSEN","suffix":null,"suffix_display":null},"covered_position":null,"new":true}],"government_entities":[{"id":32,"name":"Education, Dept of"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"INS","general_issue_code_display":"Insurance","description":"H.R. 608: COVER Now Act expands health care coverage for those in states with no Medicaid expansion funds. H.R. 957: Parity Enforcement Act of 2025 create civil penalties for violating mental health parity requirements. -- H.R. 2082: WISH Act provides long-term care insurance benefits for seniors. H.R. 3758: Workers Disability Benefits Parity Act of 2025 mandates equal treatment of mental, behavioral, and physical health conditions in disability benefit plans. H.R. 6760: Protecting Access to Affordable Coverage Act: facilitating enrollment of qualified individuals in insurance plans S. 3698/H.R. 7227: Mental Health and MAMA Act of 2026 requires group health plans and insurers to provide mental health and substance use disorder services without cost-sharing for pregnant and postpartum individuals.","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":141549,"prefix":"mr","prefix_display":"MR.","first_name":"MICHAEL","nickname":null,"middle_name":"MATTHEW","last_name":"LINSKEY","suffix":null,"suffix_display":null},"covered_position":"Legislative Correspondent for Debbie Wasserman Schultz 4/2005-10/2005","new":false},{"lobbyist":{"id":139015,"prefix":"ms","prefix_display":"MS.","first_name":"HANNAH","nickname":null,"middle_name":null,"last_name":"WESOLOWSKI","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":149684,"prefix":null,"prefix_display":null,"first_name":"JOANNA","nickname":null,"middle_name":null,"last_name":"ROSEN","suffix":null,"suffix_display":null},"covered_position":null,"new":true}],"government_entities":[{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"MMM","general_issue_code_display":"Medicare/Medicaid","description":"H.R. 1096: HOPE and Mental Wellbeing Act of 2025 mandates coverage of three annual primary care visits without cost-sharing under Medicare and Medicaid. H.R. 1867: Removes in-person requirements for mental health services under Medicare. H.R. 1598: Ensuring Access to Medicaid Buy-in Programs Act lifts the age cap for Medicaid buy-in programs for those with disabilities who choose to work S. 752/H.R. 1509: Accelerating Kids Access to Care Act expands Medicaid enrollment across state lines. S. 683: More Behavioral Health Providers Act of 2025 creates workforce incentives under Medicare. H.R. 2540: SSI Savings Penalty Elimination Act updates resource limits for SSI income eligibility. Reject cuts to Medicaid and other mental health and or substance use disorder programs in the reconciliation process. Support for state waivers for federal financial participation for services furnished to Medicaid members during short-term stays for acute care in psychiatric hospitals or residential treatment facilities that qualify as institutions for mental disease. -- H.R. 1: One Big Beautiful Bill Act reauthorizes and reforms major federal programs including Medicaid. H.R. 2590: Mental and Physical Health Care Comorbidities Act of 2025 establishes a Medicare demonstration program to promote collaborative treatment of mental and physical health comorbidities. S. 1264/H.R. 3320: Strengthening Medicaid for Serious Mental Illness Act increases federal Medicaid funding for states providing intensive community-based services for adults with serious mental illness. H.R. 4022: Increasing Behavioral Health Treatment Act removes the Medicaid exclusion for mental health services in institutions for mental diseases for patients under 65. S. 2011/H.R. 3884: Telemental Health Care Access Act removes the statutory requirement that Medicare beneficiaries be seen in-person within six months of being treated for mental and behavioral health services through telehealth. S. 2024/H.R. 3907: Expand Navigators Resources for Outreach, Learning, and Longevity (ENROLL) Act strengthens and expands the navigator program by increasing funding, broadening duties, and ensuring nonprofit participation. H.R. 2495: Nutrition CARE Act of 2025 provides Medicare coverage for medical nutrition therapy for individuals with eating disorders. H.R. 2263: Telehealth Coverage Act of 2025: permanently expands telehealth services under Medicare H.R. 3384 Telemental Health Care Access Act: Expands Medicaid to include both mental and behavioral health services provided by telehealth. H.R. 4037/S.2847: Occupational Therapy Mental Health parity Act: Clarifies that Medicare covers occupational therapy for mental health and substance use disorders HR 4619 Medicare Mental Health Impatient Equity Act of 2025: Removes the 190-day lifetime limit on Medicare coverage on inpatient Psychiatric hospital services. HR 5462: Michelle Alyssa Go Act: Would expand Medicaid coverage for mental health and substance use disorder treatment by increasing the facility size limit from 16 to 36 beds. S. 2401/H.R. 4745: Medicaid Bump Act: Increase federal Medicaid funds for certain mental health services S. 1797 Expanding Seniors Access to Mental Health Services Act: expands Medicaid coverage and reimbursement for clinical social workers to provide mental health services S.2050 ASSIST Act: Increases federal Medicaid funding for school-based behavioral health services S.2069/HR 4028: Stabilize Medicaid and CHIP Coverage Act: mandates 12-month continuous enrollment for all individuals in Medicaid and CHIP S.2037/H.R.4313 Hospital Inpatient Services Modernization Act: Extends Medicare's acute hospital care at home waiver flexibilities S.2709/ H.R.5081: Telehealth Modernization Act: Extends and expands Medicare telehealth flexibilities S.3300/H.R.6408: ANCHOR Act of 2025 allows states to expand Medicaid coverage to low income, uninsured individuals with serious mental illness or substance use disorders S.3486 Expand the Behavioral Health Workforce Now Act: Requires federal guidance to help states strengthen the behavioral health workforce in Medicaid and CHIP S. 3522 No Red Tape for Addiction Treatment Act: Requires State Medicaid programs to cover at least one formulation of each medication for opioid use disorder without prior Authorization H.R. 6096 NEST Act funds and distributes essential newborn supply kits to mothers. S.1816/ H.R. 3514: Improving Seniors' Timely Access to Care Act: Streamlining prior authorization to increase timely access to care. Support for the extension of the enhanced advance premium tax credits (eAPTC) Support for an extension or permanent authorization of telehealth/telemental health flexibilities Support for continued access to Medicaid Ensuring that new community engagement requirements do not lead to individuals being unfairly removed from Medicaid. H.R. 7535: Second Chance Mental Health Access Act of 2026 requires Medicaid to cover 12 annual mental health telehealth visits for individuals transitioning from incarceration to home confinement. H.R. 5662: Improving Access to Institutional Mental Health Care Act removes the Medicaid exclusion for coverage of services provided to patients in mental health institutions. H.R. 6296: Advancing Access to Telehealth Act makes several telehealth flexibilities permanent under Medicare. H.R. 6727: Repealing the IMD Exclusion Act removes the Medicaid exclusion for mental health and substance use disorder treatment in institutions for mental diseases. H.R. 7324: More Behavioral Health Providers Act of 2026 expands Medicare bonus payments to a wider range of behavioral health practitioners. S. 2709: Telehealth Modernization Act extends and expands Medicare telehealth flexibilities. S. 3521/H.R. 6841: PEERS Act of 2025 expands Medicare to cover peer support services for mental health and substance use recovery. S. 3690: Ensuring Access to Medicaid Buy-in Programs Act of 2026 removes the age limit for working adults with disabilities to qualify for Medicaid buy-in programs. S. 3750: REAL Health Providers Act requires Medicare Advantage plans to maintain accurate provider directories. S. 4076: Removing Medicare Mental Health Inpatient Limitations Act of 2026 removes the 190-day lifetime limit on Medicare coverage for inpatient psychiatric hospital services. S. 4202: Mental Health Access and Provider Support Act of 2026 increases Medicare reimbursement rates for certain mental health providers.","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":141549,"prefix":"mr","prefix_display":"MR.","first_name":"MICHAEL","nickname":null,"middle_name":"MATTHEW","last_name":"LINSKEY","suffix":null,"suffix_display":null},"covered_position":"Legislative Correspondent for Debbie Wasserman Schultz 4/2005- 10/2005","new":false},{"lobbyist":{"id":139015,"prefix":"ms","prefix_display":"MS.","first_name":"HANNAH","nickname":null,"middle_name":null,"last_name":"WESOLOWSKI","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":149684,"prefix":null,"prefix_display":null,"first_name":"JOANNA","nickname":null,"middle_name":null,"last_name":"ROSEN","suffix":null,"suffix_display":null},"covered_position":null,"new":true}],"government_entities":[{"id":136,"name":"Centers For Medicare and Medicaid Services (CMS)"},{"id":34,"name":"Health & Human Services, Dept of (HHS)"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":1,"name":"SENATE"},{"id":12,"name":"White House Office"}]},{"general_issue_code":"VET","general_issue_code_display":"Veterans","description":"S.926/ H.R. 1987: Saving Our Veterans Lives Act authorizes a program through the Department of Veterans Affairs to provide free firearm lockboxes to veterans. H.R. 1290: Veterans Mental Health Crisis Referral Enhancement Act of 2025 creates program to refer veterans to non-VA providers. S. 219/H.R. 71: Veterans Health Care Freedom Act allows veterans to choose their health care providers. H.R. 438: PFC Joseph P. Dwyer Peer Support Program Act creates for grants for local peer to peer mental health programs. -- H.R. 1987: Saving Our Veterans Lives Act of 2025 establishes a VA program to provide veterans with secure firearm storage solutions. H.R. 2942: What Works for Preventing Veteran Suicide Act establishes standard practices for suicide prevention and mental health programs under the Veterans Health Administration. S. 585: Servicemember to Veteran Health Care Connection Act of 2025 establishes a pre-transition health care registration process for separating Armed Forces members. S. 609/H.R. 553: BRAVE Act requires the VA to establish a mental health care outreach system for veterans within two years. S. 702/H.R. 2426: Veterans Mental Health and Addiction Therapy Quality of Care Act requires a study comparing the quality of mental health and addiction therapy care between VA and non-VA providers. H.R. 3363 VA Mental Health Outreach and Engagement Act: requires the Department of Veterans Affairs to offer annual mental health consultations and conduct outreach for Veterans with service-connected mental health disabilities. H.R. 5040 Accurate Mental Health Resources for our Servicemembers Act: Requires military branches to review, update, and certify the accuracy of their online suicide prevention and behavioral health information. S.1655: Protecting Veterans in Crisis Act: Increasing oversight, reporting, and workforce protections for the Veterans Crisis Line. S.1912: Protecting Veterans Community Care Act: Expands and Safeguards veterans' access to community-based mental health and substance use services S2853/H.R. 5420 VA Extenders Act: Extends key Department of Veterans Affairs health care, benefits, and housing programs S.3042/H.R.3627 Justice for America's Veterans and Survivors Act: Mandates data on the cause of death among Veterans, including detailed data on service-connected disabilities and suicides S.3139 H.R. 6454: VA Zero Suicide Demonstration Project Act: Establishes a 5-year pilot program at select VA medical centers to implement the Zero Suicide Institutes' suicide prevention curriculum. H.R. 6000: Veterans Sentinel Act mandates improved data collection, analysis, and reporting on suicides and attempted suicides by veterans. H.R. 6383: Brandon Act Training and Protocol Act requires a strategic plan, protocols and training to improve mental health support and suicide prevention for Armed Forces members. H.R. 6858: Veteran Suicide Prevention Act mandates review of veteran suicides in VA care. H.R. 7049: Improving Mental Health Care and Coordination for Homeless Veterans Act requires the VA to assess and coordinate care for veterans identified as needing homeless services. H.R. 7735: Improving Mental Health Support for Servicemembers and Veterans Act requires an assessment of mental health support programs for servicemembers and veterans. S. 3245: MIND Our Veterans Act of 2025 requires validated mental health and substance use screenings for departing members. S. 3758: End Veterans Overdose Act of 2026 requires the VA to provide free opioid overdose rescue medications. S. 607: Improving Veteran Access to Care Act requires the VA to modernize and improve health care appointment scheduling for veterans.","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":139015,"prefix":"ms","prefix_display":"MS.","first_name":"HANNAH","nickname":null,"middle_name":null,"last_name":"WESOLOWSKI","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":141549,"prefix":"mr","prefix_display":"MR.","first_name":"MICHAEL","nickname":null,"middle_name":"MATTHEW","last_name":"LINSKEY","suffix":null,"suffix_display":null},"covered_position":"Legislative Correspondent for Debbie Wasserman Schultz 4/2005-10/2005","new":false},{"lobbyist":{"id":149684,"prefix":null,"prefix_display":null,"first_name":"JOANNA","nickname":null,"middle_name":null,"last_name":"ROSEN","suffix":null,"suffix_display":null},"covered_position":null,"new":true}],"government_entities":[{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":1,"name":"SENATE"},{"id":42,"name":"Veterans Affairs, Dept of (VA)"}]},{"general_issue_code":"HOU","general_issue_code_display":"Housing","description":"H.R. 577: Treatment and Homelessness Housing Integration Act of 2024 allows referrals to community-based treatment. -- S. 1477/H.R. 2945: Housing for All Act of 2025 seeks to combat homelessness and the housing crisis by significantly increasing federal investments in affordable and supportive housing. Support for the renewal of HUD Continuum of Care Grants H.R. 6403: Homeless Children and Youth Act of 2025 expands definition of homelessness.","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":141549,"prefix":"mr","prefix_display":"MR.","first_name":"MICHAEL","nickname":null,"middle_name":"MATTHEW","last_name":"LINSKEY","suffix":null,"suffix_display":null},"covered_position":"Legislative Correspondent for Debbie Wassermann Schultz 4/2005-10/2005","new":false},{"lobbyist":{"id":139015,"prefix":"ms","prefix_display":"MS.","first_name":"HANNAH","nickname":null,"middle_name":null,"last_name":"WESOLOWSKI","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":149684,"prefix":null,"prefix_display":null,"first_name":"JOANNA","nickname":null,"middle_name":null,"last_name":"ROSEN","suffix":null,"suffix_display":null},"covered_position":null,"new":true}],"government_entities":[{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":1,"name":"SENATE"}]}],"conviction_disclosures":[],"foreign_entities":[],"affiliated_organizations":[]},{"url":"https://lda.gov/api/v1/filings/a4a07275-b984-4ee1-bbdb-c74b83630568/","filing_uuid":"a4a07275-b984-4ee1-bbdb-c74b83630568","filing_type":"Q1","filing_type_display":"1st Quarter - Report","filing_year":2026,"filing_period":"first_quarter","filing_period_display":"1st Quarter (Jan 1 - Mar 31)","filing_document_url":"https://lda.gov/filings/public/filing/a4a07275-b984-4ee1-bbdb-c74b83630568/print/","filing_document_content_type":"text/html","income":null,"expenses":"40000.00","expenses_method":"A","expenses_method_display":"A","posted_by_name":"Peter Mellman","dt_posted":"2026-04-16T15:23:28-04:00","termination_date":null,"registrant_country":"United States of America","registrant_ppb_country":null,"registrant_address_1":"2201 Wisconsin Ave NW","registrant_address_2":"#320","registrant_different_address":false,"registrant_city":"Washington","registrant_state":"DC","registrant_zip":"20007","registrant":{"id":401104336,"url":"https://lda.gov/api/v1/registrants/401104336/","house_registrant_id":null,"name":"VOTEVETS ACTION FUND, INC.","description":"Advocating for US military veterans and their families","address_1":"25 Massachusetts Avenue NW","address_2":"500k","address_3":null,"address_4":null,"city":"Washington","state":"DC","state_display":"District of Columbia","zip":"20001","country":"US","country_display":"United States of America","ppb_country":"US","ppb_country_display":"United States of America","contact_name":"PETER MELLMAN","contact_telephone":"+1 646-415-8429","dt_updated":"2026-07-15T14:37:57.590761-04:00"},"client":{"id":201544,"url":"https://lda.gov/api/v1/clients/201544/","client_id":12,"name":"VOTEVETS ACTION FUND, INC.","general_description":null,"client_government_entity":false,"client_self_select":true,"state":"DC","state_display":"District of Columbia","country":"US","country_display":"United States of America","ppb_state":"DC","ppb_state_display":"District of Columbia","ppb_country":"US","ppb_country_display":"United States of America","effective_date":"2017-02-28"},"lobbying_activities":[{"general_issue_code":"LBR","general_issue_code_display":"Labor Issues/Antitrust/Workplace","description":"Lobbied in support of H.R.20/S.852, the Protecting the Right to Organize (PRO) Act of 2025.","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":94608,"prefix":null,"prefix_display":null,"first_name":"MARY","nickname":null,"middle_name":null,"last_name":"KASZYNSKI","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"DEF","general_issue_code_display":"Defense","description":"Lobbied in support of H.R. 8175, To amend title 10, United States Code, and the National Defense Authorization Act for Fiscal Year 1994, to codify and clarify gender neutral standards for members of certain Armed Forces, and for other purposes.","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":94608,"prefix":null,"prefix_display":null,"first_name":"MARY","nickname":null,"middle_name":null,"last_name":"KASZYNSKI","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"GAM","general_issue_code_display":"Gaming/Gambling/Casino","description":"Lobbied in support of S.4115, BETS OFF Act.","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":94608,"prefix":null,"prefix_display":null,"first_name":"MARY","nickname":null,"middle_name":null,"last_name":"KASZYNSKI","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"FOR","general_issue_code_display":"Foreign Relations","description":"Lobbied in support of S.J.Res.123, A joint resolution to direct the removal of United States Armed Forces from hostilities within or against the Islamic Republic of Iran that have not been authorized by Congress. Lobbied in support of S.J.Res.118, A joint resolution to direct the removal of United States Armed Forces from hostilities within or against the Islamic Republic of Iran that have not been authorized by Congress. Lobbied in support of S.J.Res.117, A joint resolution to direct the removal of United States Armed Forces from hostilities within or against the Islamic Republic of Iran that have not been authorized by Congress. Lobbied in support S.J.Res.116, A joint resolution to direct the removal of United States Armed Forces from hostilities within or against the Islamic Republic of Iran that have not been authorized by Congress. Lobbied in support of S.J.Res.115, A joint resolution to direct the removal of United States Armed Forces from hostilities within or against the Islamic Republic of Iran that have not been authorized by Congress. Lobbied in support of S.J.Res.104, A joint resolution to direct the removal of United States Armed Forces from hostilities within or against the Islamic Republic of Iran that have not been authorized by Congress. Lobbied in support of H.Con.Res.75, Directing the President, pursuant to section 5(c) of the War Powers Resolution, to remove the United States Armed Forces from hostilities against the Islamic Republic of Iran. Lobbied in support of H.Con.Res. 40, Directing the President, pursuant to section 5(c) of the War Powers Resolution, to remove United States Armed Forces from hostilities with Iran.","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":94608,"prefix":null,"prefix_display":null,"first_name":"MARY","nickname":null,"middle_name":null,"last_name":"KASZYNSKI","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"VET","general_issue_code_display":"Veterans","description":"Lobbied in support of H.J.Res.144/S.J.Res.103, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Department of Veterans Affairs relating to \"Reproductive Health Services.\" Lobbied in support of S.3466, Honor Our Promise to Veterans Act of 2025. Lobbied in support of H.R.7841, Warrior Infertility Act. Lobbied in support of H.R.220, Veterans Infertility Treatment Act.","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":94608,"prefix":null,"prefix_display":null,"first_name":"MARY","nickname":null,"middle_name":null,"last_name":"KASZYNSKI","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":1,"name":"SENATE"}]}],"conviction_disclosures":[],"foreign_entities":[],"affiliated_organizations":[]},{"url":"https://lda.gov/api/v1/filings/b8c6751f-32c8-438b-b138-cfd3b964b2b1/","filing_uuid":"b8c6751f-32c8-438b-b138-cfd3b964b2b1","filing_type":"Q1","filing_type_display":"1st Quarter - Report","filing_year":2026,"filing_period":"first_quarter","filing_period_display":"1st Quarter (Jan 1 - Mar 31)","filing_document_url":"https://lda.gov/filings/public/filing/b8c6751f-32c8-438b-b138-cfd3b964b2b1/print/","filing_document_content_type":"text/html","income":null,"expenses":"250000.00","expenses_method":"A","expenses_method_display":"A","posted_by_name":"Michael Monroe","dt_posted":"2026-04-17T10:30:14-04:00","termination_date":null,"registrant_country":"United States of America","registrant_ppb_country":null,"registrant_address_1":"815 16TH STREET, NW, #600","registrant_address_2":null,"registrant_different_address":false,"registrant_city":"WASHINGTON","registrant_state":"DC","registrant_zip":"20006","registrant":{"id":7383,"url":"https://lda.gov/api/v1/registrants/7383/","house_registrant_id":31785,"name":"BUILDING AND CONSTRUCTION TRADES DEPT., AFL-CIO","description":null,"address_1":"815 16TH STREET, NW, #600","address_2":null,"address_3":null,"address_4":null,"city":"WASHINGTON","state":"DC","state_display":"District of Columbia","zip":"20006","country":"US","country_display":"United States of America","ppb_country":"US","ppb_country_display":"United States of America","contact_name":"MICHAEL MONROE","contact_telephone":"+1 202-756-4560","dt_updated":"2026-07-06T13:19:04.484234-04:00"},"client":{"id":110731,"url":"https://lda.gov/api/v1/clients/110731/","client_id":12,"name":"BUILDING AND CONSTRUCTION TRADES DEPT AFL-CIO","general_description":null,"client_government_entity":false,"client_self_select":true,"state":"DC","state_display":"District of Columbia","country":"US","country_display":"United States of America","ppb_state":"DC","ppb_state_display":"District of Columbia","ppb_country":"US","ppb_country_display":"United States of America","effective_date":"2007-08-14"},"lobbying_activities":[{"general_issue_code":"BUD","general_issue_code_display":"Budget/Appropriations","description":"H.R. 3548. Infrastructure Expansion Act. A bill to preclude absolute liability in any action against a property owner or contractor for projects receiving Federal financial assistance for infrastructure and transportation development, and for other purposes. Bill in full. No bill number. Lobbied on the Surface Transportation Reauthorization.Entire bill. S.J. Res. 37. A joint resolution. A joint resolution terminating the national emergency declared to impose duties on articles imported from Canada. Bill in full. H.R. 1. One Big Beautiful Act. This bill reduces taxes, reduces or increases spending for various federal programs, increases the statutory debt limit, and otherwise addresses agencies and programs throughout the federal government. Lobbied on prevailing wage and Registered Apprenticeship, Medicaid impact on multiemployer health plans, resurrection of the Cadillac tax and clean energy tax credits. No bill number. Lobbied on the impact of tariffs. No bill number. Lobbied on labor standards on tax credits within the Inflation Reduction Act. No bill number. Lobbied on funding cuts to the Departments of Labor, Health and Human Services, Transportation, Energy, Interior, Commerce and Treasury. No bill number. Lobbied on transportation projects funding.","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":139706,"prefix":"mr","prefix_display":"MR.","first_name":"JAMES","nickname":null,"middle_name":"CLARK","last_name":"BREWER","suffix":"jr","suffix_display":"JR"},"covered_position":null,"new":false},{"lobbyist":{"id":137907,"prefix":"mr","prefix_display":"MR.","first_name":"TREVOR","nickname":null,"middle_name":null,"last_name":"FALK","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":60142,"prefix":null,"prefix_display":null,"first_name":"ROSS","nickname":null,"middle_name":null,"last_name":"MARADIAN","suffix":null,"suffix_display":null},"covered_position":"Rep. Leonard Boswell - Legislative Director/Legislative Assistant/Staff Assistant","new":false}],"government_entities":[{"id":11,"name":"Executive Office of the President (EOP)"},{"id":172,"name":"Federal Aviation Administration (FAA)"},{"id":173,"name":"Federal Highway Administration (FHA)"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":38,"name":"Labor, Dept of (DOL)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"ENG","general_issue_code_display":"Energy/Nuclear","description":"No bill number. Lobbied for permitting reform and federally funded energy programs. No bill number. Lobbied on the CERTAIN ACT (Create Expedited Reviews To Transform American Infrastructure Now) - transform the federal permitting process and meet Americas energy and electricity needs. S.3682. Power for the People Act of 2026. A bill to promote the creation of data center load queues and data center-specific rate classes to mitigate the impact of data centers on other electricity consumers, and for other purposes. Lobbied for the inclusion of labor standards. H.R.3474. Federal Mechanical Insulation Act. A bill to clarify that the installation of mechanical insulation property is an energy or water efficiency measure that may be used in Federal buildings for purposes of section 543(f) of the National Energy Conservation Policy Act, and for other purposes. Bill in full. No bill number. Lobbied on the Energy Bills Relief Act - that ensures Americans have access to the most reliable and low-cost source of power available, renewable energy. No bill number. Lobbied on the growing energy workforce. No bill number. Lobbied on attaching labor standards to data center legislation, against data center bans and data centers overall. No Bill Number - Advocated for various energy tax credits. No bill number - Advocated in support of unionized mining efforts across the country and the further expansion of utilizing critical mineral resource. No bill number - Advocated for the domestic uranium supply chain and increased funding for advanced fuels. No bill number - Advocated for the continued functioning of the Tennessee Valley Authority. No bill number - Engaged congress on RIN relief and renewable fuel standards. No bill number. Lobbied on Offshore Wind. No bill number. Lobbied on Mining and energy production on federal land. No bill number. Lobbied on maintaining existing grants and loans No bill number. Lobbied on National Laboratories No bill number. Lobbied on Nuclear development and funding No bill number. Lobbied on Nuclear Fuel Enrichment and Funding No bill number. Lobbied on Defense Production Act and nuclear energy No bill number. Lobbied on Loan Programs Office No bill number. Lobbied on Carbon Capture Facilities No bill number. Lobbied on support for nuclear clean-up sites No bill number. Lobbied on recruiting and training for the nuclear industry","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":139706,"prefix":"mr","prefix_display":"MR.","first_name":"JAMES","nickname":null,"middle_name":"CLARK","last_name":"BREWER","suffix":"jr","suffix_display":"JR"},"covered_position":null,"new":false},{"lobbyist":{"id":137907,"prefix":"mr","prefix_display":"MR.","first_name":"TREVOR","nickname":null,"middle_name":null,"last_name":"FALK","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":60142,"prefix":null,"prefix_display":null,"first_name":"ROSS","nickname":null,"middle_name":null,"last_name":"MARADIAN","suffix":null,"suffix_display":null},"covered_position":"Rep. Leonard Boswell - Legislative Director/Legislative Assistant/Staff Assistant","new":false}],"government_entities":[{"id":24,"name":"Commerce, Dept of (DOC)"},{"id":33,"name":"Energy, Dept of"},{"id":11,"name":"Executive Office of the President (EOP)"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":36,"name":"Interior, Dept of (DOI)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"LBR","general_issue_code_display":"Labor Issues/Antitrust/Workplace","description":"No bill number. Lobbied in support of pre-apprenticeship and registered apprenticeship programs in the construction industry. No bill number. Lobbied on worker misclassification. No bill number. Lobbied on project labor agreements. No bill number. Lobbied on Davis-Bacon. No bill number. Lobbied on veteran use of GI benefits for registered apprenticeship. No bill number. Lobbied on federally funded prevailing wage. H.R. 7115. Jumpstart Savings Act. A bill to amend the Internal Revenue Code of 1986 to establish Jumpstart Programs for saving for apprenticeship and trade occupation training, and for other purposes. Bill in full. S.3993. Reducing Arbitrary Barriers to Apprenticeship Act of 2026. A bill to amend title 38, United States Code, and title 10, United States Code, to eliminate those provisions relating to veterans educational assistance that disadvantage eligible individuals who choose to pursue programs of apprenticeship or other on-job training instead of a four-year college degree, and for other purposes. Bill in full. H.R. 982. Warriors to Workforce Act. A bill to amend title 38, United States Code, to increase the amount of educational assistance paid by the Secretary of Veterans Affairs to an eligible individual during the first year of a full-time program of apprenticeship or other on-job training. Bill in full. S. 852. Richard L. Trumka Protecting the Right to Organize Act of 2025. This bill expands various labor protections related to employees' rights to organize and collectively bargain in the workplace. Bill in full. H.R. 20. Richard L. Trumka Protecting the Right to Organize Act of 2025. This bill expands various labor protections related to employees' rights to organize and collectively bargain in the workplace. Bill in full. H.R. 3944. Military Construction, Veterans Affairs, and Related Agencies Appropriations Act of 2026. Lobbied on amendments regarding project labor agreements, prevailing wage and Registered Apprenticeship. H.R.5408. Faster Labor Contracts Act. A bill to accelerate workplace time-to-contract under the National Labor Relations Act. Bill in full. S.844. Faster Labor Contracts Act. A bill to accelerate workplace time-to-contract under the National Labor Relations Act. Bill in full. No bill number. Lobbied on attaching labor standards to data center legislation, against data center bans and data centers overall. No bill number. Lobbied on pension and health care issues impacting construction workers. No bill number. Lobbied on the issue of childcare affordability for construction workers. No bill number. Lobbied on the issue of mental health crisis and opioid epidemic in the construction industry. No bill number. Lobbied on the issue of paid sick leave for construction workers. No bill number. Lobbied on safety and health issues on the jobsite impacting construction workers. No bill number. Lobbied for the inclusion of Registered Apprenticeship utilization on military construction projects. No bill number. Lobbied against Industry Recognized Apprenticeship Programs being applicable to the construction industry. No bill number. Lobbied on federal prevailing wage. No bill number. Lobbied for access to construction projects on domestic military installations. No bill number. Lobbied on the nomination of John Berry to be Solicitor General of the Department of Labor. No bill number. Lobbied on the nomination of Andrew Rogers to be Wage and Hour Administrator at the Department of Labor. No bill number. Discussion draft. Reauthorization of the Workforce Innovation and Opportunity Act. Lobbied on youth apprenticeship. No bill number. Discussion draft. Lobbied on Registered Apprenticeship reciprocity in states, new Advisory Council on Apprenticeship, Apprenticeship Application Approval and creating more Registered Apprenticeships in rural areas. No bill number. Lobbied on the impact of Artificial Intelligence on the construction industry. No bill number. Lobbied on housing proposals regarding application of prevailing wage. No bill number. Lobbied on the application of labor standards on housing related federal tax credits. No bill number. Discussion draft. Lobbied on the application of prevailing wage to housing projects funded or financed by the federal government. No bill number. Discussion draft. Lobbied on the application of prevailing wage to housing projects, spurred by application of the Defense Production Act, funded or financed by the federal government. No bill number. Discussion draft. Lobbied on child labor protections and Registered Apprenticeship when federal funding is allocated to local and state education agencies for creating shop classes in schools. No bill number. Lobbied on women in the construction industry. No bill number. Lobbied on prevailing wage application on Cape Canaveral projects. No bill number. Lobbied on FHWA approval of grants and PLAs. No bill number. Lobbied on implementation of the IIJA. No bill number. Lobbied on labor standards in the shipbuilding industry.","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":139706,"prefix":"mr","prefix_display":"MR.","first_name":"JAMES","nickname":null,"middle_name":"CLARK","last_name":"BREWER","suffix":"jr","suffix_display":"JR"},"covered_position":null,"new":false},{"lobbyist":{"id":60142,"prefix":null,"prefix_display":null,"first_name":"ROSS","nickname":null,"middle_name":null,"last_name":"MARADIAN","suffix":null,"suffix_display":null},"covered_position":"Rep. Leonard Boswell - Legislative Director/Legislative Assistant/Staff Assistant","new":false},{"lobbyist":{"id":137907,"prefix":"mr","prefix_display":"MR.","first_name":"TREVOR","nickname":null,"middle_name":null,"last_name":"FALK","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":11,"name":"Executive Office of the President (EOP)"},{"id":65,"name":"General Services Administration (GSA)"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":38,"name":"Labor, Dept of (DOL)"},{"id":18,"name":"Office of Management & Budget (OMB)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"ENV","general_issue_code_display":"Environment/Superfund","description":"No bill number. Lobbied on National Environmental Policy Act Reform and permitting reform broadly. No bill number. Lobbied on the 2026 Water Resources Development Act. Bill in full. HR 4776 - Speed Act - To amend the National Environmental Policy Act of 1969 to clarify ambiguous provisions and facilitate a more efficient, effective, and timely environmental review process. Advocated for various permitting reform provisions. H.J. Res 140 - Superior National Forest Land Withdrawal - Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Bureau of Land Management relating to Public Land Order No. 7917 for Withdrawal of Federal Lands; Cook, Lake, and Saint Louis Counties, MN.","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":137907,"prefix":"mr","prefix_display":"MR.","first_name":"TREVOR","nickname":null,"middle_name":null,"last_name":"FALK","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":60142,"prefix":null,"prefix_display":null,"first_name":"ROSS","nickname":null,"middle_name":null,"last_name":"MARADIAN","suffix":null,"suffix_display":null},"covered_position":"Rep. Leonard Boswell - Legislative Director/Legislative Assistant/Staff Assistant","new":false},{"lobbyist":{"id":139706,"prefix":"mr","prefix_display":"MR.","first_name":"JAMES","nickname":null,"middle_name":"CLARK","last_name":"BREWER","suffix":"jr","suffix_display":"JR"},"covered_position":null,"new":false}],"government_entities":[{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"HOU","general_issue_code_display":"Housing","description":"HR 5878. HOME Reform Act of 2025. To amend the Cranston-Gonzalez National Affordable Housing Act to encourage expansion of the supply of decent, safe, sanitary, and affordable housing, with primary attention to rental housing. Bill in full. S. 3464. Housing Building Occupancy Opportunities for Millions Act. A bill to increase the housing supply in the United States. Bill in full. S.2651. ROAD to Housing Act of 2025. A bill to increase the supply of affordable housing in America. Lobbied on the application of prevailing wage. H.R.6644. Housing for the 21st Century Act. A bill to increase the supply of housing in America, and for other purposes. Lobbied on the application of prevailing wage. H.R. 6644 (as amended). 21st Century ROAD to Housing Act. To increase the supply of housing in America, and for other purposes. Lobbied on the application of prevailing wage, modular housing and offsite manufacturing of housing. No bill number. Lobbied on creation of HUD funding program for housing projects with pension monies.","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":60142,"prefix":null,"prefix_display":null,"first_name":"ROSS","nickname":null,"middle_name":null,"last_name":"MARADIAN","suffix":null,"suffix_display":null},"covered_position":"Rep. Leonard Boswell - Legislative Director/Legislative Assistant/Staff Assistant","new":false}],"government_entities":[{"id":11,"name":"Executive Office of the President (EOP)"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"IMM","general_issue_code_display":"Immigration","description":"No bill number. Lobbied on H2B Visa Reform. No bill number. Lobbied on the abuse of the E-Visa program. S. 2106 - Secure Act - Safe Environment from Countries Under Repression and Emergency Act - A bill to provide a process for granting lawful permanent resident status to aliens from certain countries who meet certain eligibility requirements. Bill in full.","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":60142,"prefix":null,"prefix_display":null,"first_name":"ROSS","nickname":null,"middle_name":null,"last_name":"MARADIAN","suffix":null,"suffix_display":null},"covered_position":"Rep. 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H.R. 3162, Affordable and Safe Prescription Drug Importation Act, entire bill 6. H.R. 3415, Nurse Staffing Standards for Hospital Patient Safety and Quality Care Act of 2025, entire bill 7. S. 1709, Nurse Staffing Standards for Hospital Patient Safety and Quality Care Act of 2025, entire bill 8. S. 2524, Restoring Essential Healthcare Act, entire bill 9. H.R. 4796, Restoring Essential Healthcare Act, entire bill 10. S. 2824, A bill to amend the Internal Revenue Code of 1986 to extend the temporary enhanced premium credits, entire bill 11. H.R. 5145, Bipartisan Premium Tax Credit Extension Act, entire bill 12. H.R. 2082, Well-Being Insurance for Seniors to be at Home Act, entire bill 13. S. 3829, Corporate Crimes Against Health Care Act, entire bill","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":30310,"prefix":"mr","prefix_display":"MR.","first_name":"RICHARD","nickname":null,"middle_name":"J","last_name":"FIESTA","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":139719,"prefix":"mr","prefix_display":"MR.","first_name":"DAVID","nickname":null,"middle_name":null,"last_name":"SIMON","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"MMM","general_issue_code_display":"Medicare/Medicaid","description":"1. CMS rule on policy and technical changes to the Medicare Advantage program 2. Expand Medicare and Medicaid coverage of anti-obesity medicines 3. Proposals to reduced Medicaid funding 4. 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Proposals to change the Social Security earnings cap 5. Proposals to change the Social Security withholding tax and increase benefits 6. H.R. 1700, Social Security Expansion Act, entire bill 7. S. 700, Social Security Expansion Act, entire bill 8. S. 1234, SSI Savings Penalty Elimination Act, entire bill 9. H.R. 1876, Keeping Our Field Offices Open Act, entire bill 10. H.R. 1877, Protecting Americans SocialSecurity Data Act, entire bill 11. Treatment of caregivers under the Social Security Act 12. Proposals to increase the Social Security death benefit 13. S. 2335, Pensions for All Act, entire bill 14. S. 2763, Keep Billionaires Out of Social Security Act, entire bill 15. S. 2614, Protecting and Preserving Social Security Act, entire bill 16. H.R. 4968, Protecting and Preserving Social Security Act, entire bill 17. S. 3462, Safeguarding American Families and Expanding Social Security Act of 2025, entire bill 18. S. 5178, Social Security Survivor Benefits Equity Act, entire bill 19. S. 3255, Surviving Widow(er) Income Fair Treatment Act of 2025, entire bill 20. S. 3462, Safeguarding American Families and Expanding Social Security Act, entire bill 21. H.R. 6084, ERISA Litigation Reform Act, entire bill 22. H.Res. 1059, Of inquiry requesting the President of the United States to furnish certain information to the House of Representatives relating to the Department of Government Efficiency's access to and usage of NUMIDENT and other personally identifiable information in the possession of the Social Security Administration, entire resolution 23. H.R. 7828, Supplemental Security Income Restoration Act, entire bill 24. S. 4001, Supplemental Security Income Restoration Act of 2026, entire bill 25. 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