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On these Bills, A New Policy lobbied in support of those that advance justice and peace, and which reduce U.S. complicity in violations of international humanitarian law, and against those that run counter to U.S. interests and values by deepening such complicity, or by doing direct harm to vital U.S. partnerships and global public diplomacy objectives. Engagement on related legislation addressed the following bills: A New Policy also engaged with the U.S. State Department on a narrow set of specific humanitarian cases of concern. H.Res.1146House Resolution Standing with the People of Lebanon Against the Illegal Invasion, War Crimes, and Ethnic Cleansing Perpetrated by the State of Israel H.Con.Res.83 The Lebanon War Powers & Oversight H.R. 7903The Justice for Hind Rajab Act H.R.7565 Food for Palestinian Children and Families in Palestinian Human Rights Act of 2026 H.Res 1092Condemning Israeli settlement expansion, settler violence, and related human rights abuses in the West Bank, and calling for Governance & Accountability and specific United States policy responses to deter further violations and protect the viability of a negotiated two-State solution H.R.4655 United States-Israel PTSD Collaborative Research Act H.R. 7645The Ceasefire Compliance Act of 2026 H.R. 7545Defending the Human Rights of Palestinian Children and Families Living Under Israeli Military Occupation Act H.R. 7540To enhance bilateral defense cooperation between the United States and Israel, and for other purposes. H.R. 7281To require a report on the death of Shireen Abu Akleh. H.R. 7178U.S.-Israel Anti-Killer Drone Act H.R. 7018To limit funding for United States participation in the United Nations if Israel is illegally expelled H.res 839Condemning Hamas for assassinating innocent Palestinians H.Res 876Recognizing the genocide of the Palestinian people in Palestinian Human Rights H.Res 769Affirming the State of Palestine's right to exist H.R. 4473The U.S.-Israel Bilateral Innovation for Research and Development (BIRD) Health Act of 2025 H.R. 1136The Make Palestinian Human Rights Great Again act H.R. 1229United States-Israel Defense Partnership Act of 2025 H.R. 23Illegitimate Court Counteraction Act H.R. 902RECOGNIZING Judea and Samaria Act H.R. 2065Unmasking Hamas Act of 2025 H.R. 3045West Bank Violence Prevention Act of 2025 H.R. 2411 UNRWA Funding Emergency Restoration Act of 2025 H.J.Res 83Providing for congressional disapproval of the proposed foreign military sale to Israel of certain defense articles and services H.J.Res 84Providing for congressional disapproval of the proposed foreign military sale to Israel of certain defense articles and services H.J.Res 85Providing for congressional disapproval of the proposed foreign military sale to Israel of certain defense articles and services H.J.Res 86Providing for congressional disapproval of the report of enhancement or upgrade of sensitive foreign military related to a sale to the Government of Israel of certain defense articles and services H.R. 3565To provide for a limitation on the transfer of defense articles and defense services to Israel H.Res. 473Calling for the urgent delivery and disbursement of humanitarian aid to address the needs of civilians in Palestinian Human Rights. H.R. 3727Supporting American Allies Act H.Con.Res. 38Directing the President pursuant to section 5(c) of the War Powers & Oversight to remove United States Armed Forces from unauthorized hostilities in the Islamic Republic of Iran H.R. 4051To address hostile and antisemitic conduct by the Republic of South Africa H.Con.Res. 40Directing the President, pursuant to section 5(c) of the War Powers & Oversight, to remove United States Armed Forces from hostilities with Iran H.R. 4281The Bunker Buster Act of 2025 S. 4240The American Homes First Act S.J.Res.136Providing for congressional disapproval of the proposed foreign military sale to the Government of Israel of certain defense articles and services S.J.Res.138Providing for congressional disapproval of the proposed foreign military sale to the Government of Israel of certain defense articles and services S.J.Res.137Providing for congressional disapproval of the proposed foreign military sale to the Government of Israel of certain defense articles and services S.J.Res.123To 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. S.J.Res.118To 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. S.J.Res.117To 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. S.J.Res.116To 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. S.J.Res.115To 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. S.4095The Justice for Hind Rajab Act S. 3855To enhance bilateral defense cooperation between the United States and Israel, and for other purposes. S. 3634Aware Act S. 3273American Allies Protection Act S. 2667West Bank Violence Prevention Act of 2025 S.Res 410 \"A resolution calling on the President to recognize a demilitarized State of Palestine, as consistent with international law and the principles of a two-state solution, alongside a secure State of Israel.\" S. 2672To codify Executive Order 14115 imposing certain sanctions on persons undermining peace, security, and stability in the West Bank S.J. Res 70A joint resolution providing for congressional disapproval of the proposed foreign military sale to Israel of certain defense articles and services S.J.Res. 59A joint resolution to direct the removal of United States Armed Forces from hostilities against the Islamic Republic of Iran that have not been authorized by Congress S.J. Res. 41A joint resolution providing for congressional disapproval of the proposed export of certain defense articles to Israel. (Analysis N/A) S.J. Res. 34A joint resolution providing for congressional disapproval of the proposed foreign military sale to the Government of Israel of certain defense articles and services S. 493Stop the ICC Act S. 554A bill to enhance bilateral defense cooperation between the United States and Israel, and for other purposes. S. 1159Palestinian Human Rights Act S.Res. 227A resolution condemning Hamas for its premeditated, coordinated, and brutal terrorist attacks on October 7, 2023, against Israel and demanding that Hamas immediately release all remaining hostages and return them to safety, and for other purposes. S.J Res 20A joint resolution providing for congressional disapproval of the proposed foreign military sale to Israel of certain defense articles and services S.J Res 21A joint resolution providing for congressional disapproval of the proposed foreign military sale to Israel of certain defense articles and services S.J Res22A joint resolution providing for congressional disapproval of the proposed foreign military sale to Israel of certain defense articles and services S.J Res 23A joint resolution providing for congressional disapproval of the proposed license amendment for the export to Israel of certain defense articles and services S.J Res 32A joint resolution providing for congressional disapproval of the proposed foreign military sale to the Government of Israel of certain defense articles and services S.J Res 33A joint resolution providing for congressional disapproval of the proposed foreign military sale to the Government of Israel of certain defense articles and services S.J Res 35A joint resolution providing for congressional disapproval of the proposed foreign military sale to the Government of Israel of certain defense articles and services S.Res 68A resolution expressing the sense of the Senate that the United States shall not deploy United States military assets or personnel to Palestinian Human Rights for purposes of \"taking over\" Palestinian Human Rights. S. Res 224A resolution calling for the urgent delivery of humanitarian aid to address the needs of civilians in Palestinian Human Rights S. 898 UNRWA Funding Emergency Restoration Act of 2025 S. 2087the No War Against Iran Act S. 384RECOGNIZING Judea and Samaria Act","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":147535,"prefix":null,"prefix_display":null,"first_name":"JOSHUA","nickname":null,"middle_name":null,"last_name":"PAUL","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":1,"name":"SENATE"},{"id":39,"name":"State, Dept of (DOS)"}]},{"general_issue_code":"CIV","general_issue_code_display":"Civil Rights/Civil Liberties","description":"A New Policy lobbied in opposition to the bills that would directly or indirectly constrain First Amendment rights, discriminate based on political views, or threaten other Constitutionally-protected freedoms, and in support of Bills that protect the right of citizens and visitors to the U.S. to express protected political speech. H.R. 7156The SCAM Act H.R. 7060A bill to stop the Government from attacking individuals and organizations for their political speech or participation H.R. 6800To amend the Internal Revenue Code of 1986 to terminate the tax-exempt status of terrorist supporting organizations H.R. 6186No Antisemitism in Education Act H.R. 4795Protect Economic and Academic Freedom Act of 2025 H.R. 5011Violent Antisemitism Threat Assessment Act H.R. 4983Kotel Act H.R. 1007Antisemitism Awareness Act of 2025 H.R. 1033COLUMBIA Act of 2025 H.R. 2866No Visas for Anti-Semitic Students Act H.R 3208No Official Palestine Entry Act of 2025 H.R. 867IGO Anti-Boycott Act H.R. 3282Preventing Antisemitic Harassment on Campus Act of 2025 H.R. 3050 Countering Hate Against Israel by Federal Contractors Act H.R. 277Matthew Lawrence Perna Act of 2025 H.R. 3724No Amnesty for Hamas Sympathizers Act S. 3674The SCAM Act S.3646A bill to stop the Government from attacking individuals and organizations for their political speech or participation S. 3554To amend the Internal Revenue Code of 1986 to terminate the tax-exempt status of terrorist supporting organizations S. 856 Disclosing Foreign Influence in Lobbying ActS. 558Antisemitism Awareness Act of 2025 S. 937No Student Loans for Campus Criminals Act S. 1612No Official Palestine Entry (NOPE) Act S. 826Preventing Antisemitic Harassment on Campus Act of 2025","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":147535,"prefix":null,"prefix_display":null,"first_name":"JOSHUA","nickname":null,"middle_name":null,"last_name":"PAUL","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/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. 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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/9c34701c-f71d-4d65-81bc-130fe4e15d4b/","filing_uuid":"9c34701c-f71d-4d65-81bc-130fe4e15d4b","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/9c34701c-f71d-4d65-81bc-130fe4e15d4b/print/","filing_document_content_type":"text/html","income":null,"expenses":"350000.00","expenses_method":"A","expenses_method_display":"A","posted_by_name":"David Cetola","dt_posted":"2026-04-13T14:19:58-04:00","termination_date":null,"registrant_country":"United States of America","registrant_ppb_country":null,"registrant_address_1":"2564 US Highway 1","registrant_address_2":null,"registrant_different_address":true,"registrant_city":"Lawrence","registrant_state":"NJ","registrant_zip":"08648","registrant":{"id":400408933,"url":"https://lda.gov/api/v1/registrants/400408933/","house_registrant_id":null,"name":"SYENSQO USA LLC","description":"Solvay manufactures an extensive range of chemicals and plastics such as soda ash, etc.","address_1":"2564 US Highway 1","address_2":null,"address_3":null,"address_4":null,"city":"Lawrence","state":"NJ","state_display":"New Jersey","zip":"08648","country":"US","country_display":"United States of America","ppb_country":"US","ppb_country_display":"United States of America","contact_name":"DAVE CETOLA","contact_telephone":"+1 609-819-5900","dt_updated":"2026-07-02T20:03:19.523398-04:00"},"client":{"id":190355,"url":"https://lda.gov/api/v1/clients/190355/","client_id":12,"name":"SYENSQO USA LLC","general_description":null,"client_government_entity":false,"client_self_select":true,"state":"TX","state_display":"Texas","country":"US","country_display":"United States of America","ppb_state":"TX","ppb_state_display":"Texas","ppb_country":"US","ppb_country_display":"United States of America","effective_date":"2009-03-17"},"lobbying_activities":[{"general_issue_code":"AER","general_issue_code_display":"Aerospace","description":"H.R. 3838, S. 2296, National Defense Authorization Act for Fiscal Year 2026, including provisions related to the procurement of aircraft. 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Technology export license governed by U.S. Department of Commerce Bureau of Industry and Security's Export Administration Regulations. 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Potential bills for National Defense Authorization for Fiscal Year 2027, including provisions related to the regulation of PFAS and CERCLA liability waivers. Discussion Draft of Legislation to Modernize the Toxic Substances Control Act, including provisions related to updating EPA's TSCA review process. H.R. 1267, Water Systems PFAS Liability Protection Act, including provisions related to CERCLA exemptions for PFAS liability. H.R. 1415, S. 623, No IRIS Act, including provisions related to the use of assessments generated by the IRIS program. Potential Senate legislation directing EPA to regulate PFAS in certain sectors and environmental media, and exemptions to CERCLA liability. Potential Senate legislation to reform TSCA Section 5 requirements for significant new use notices. EPA's Advanced Notice of Proposed Rulemaking, Clean Water Act Effluent Limitations Guidelines and Standards for Organic Chemicals, Plastics and Synthetic Fibers Point Source Category. EPA's Rule on TSCA 8(a)(7) Reporting and Recordkeeping Requirements for PFAS Substances. EPA's New Chemical Review process under TSCA, including the process to approve new chemicals, low volume and polymer exemptions from TSCA's pre-manufacture notice requirements. EPA's final rule on National Primary Drinking Water Regulation for six PFAS, including PFOA, PFOS, PFNA, HFPO-DA, PFHxS and PFBS. EPA's final rule on designations of PFAS as CERCLA Hazardous Substances. EPA's proposed Toxic Substances Control Act risk management rule for Trichloroethylene (TCE), EPA-HQ-OPPT-2020-0642-0026, 88 Fed. Reg. 74,712 (Oct. 31, 2023). EPA's proposed rule on Procedures for Chemical Risk Evaluation under the Toxic Substances Control Act, EPA-HQ-OPPT-2023-0496, 88 Fed. Reg. 74,292 (Oct. 30, 2023). EPA's final revised risk determination for 1,4-dioxane under the Toxic Substances Control Act, EPA-HQ-OPPT-2016-0723, 89 Fed. Reg. 89,993 (Nov. 14, 2024). EPA's draft scope of the risk evaluation for vinyl chloride under the Toxic Substances Control Act, EPA-HQ-OPPT-2018-0448, 90 Fed. Reg. 4,738 (Jan. 16, 2025). EPA Pesticides Registration, Product code DV 5-26762 (Actizone), Reg. No. 4564-27.","foreign_entity_issues":"As parent entities of Syensqo USA LLC, Syensqo SA and Syensqo France SA have a generalized interest in the issues above.","lobbyists":[{"lobbyist":{"id":80986,"prefix":null,"prefix_display":null,"first_name":"DAVID","nickname":null,"middle_name":null,"last_name":"CETOLA","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":147477,"prefix":"mr","prefix_display":"MR.","first_name":"JAMES","nickname":null,"middle_name":"KA CHUN","last_name":"LAI","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":147511,"prefix":null,"prefix_display":null,"first_name":"IAN","nickname":null,"middle_name":null,"last_name":"CHOINIERE","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":24,"name":"Commerce, Dept of (DOC)"},{"id":25,"name":"Defense, Dept of (DOD)"},{"id":49,"name":"Environmental Protection Agency (EPA)"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"DEF","general_issue_code_display":"Defense","description":"Department of Defense's Defense Production Act Title III program and Industrial Base Analysis and Sustainment (IBAS) program, including funding for projects that support national security. H.R. 3838, S. 2296, National Defense Authorization Act for Fiscal Year 2026, including provisions related to the support for the defense industrial base, reporting on uses of PFAS that are critical to national security. S. 4212, Prioritizing the Warfighter in Defense Contracting Act of 2026, including provisions related to prohibiting stock buybacks, dividends and caps compensation as a condition of contracting with the Department of Defense. Department of Defense Appropriations Act, 2027, including provisions related to national security projects under the Industrial Base Analysis and Sustainment (IBAS) program. Department of Defense Appropriations Act, 2026, including provisions related to national security projects under the Industrial Base Analysis and Sustainment (IBAS) program.","foreign_entity_issues":"As parent entities of Syensqo USA LLC, Syensqo SA and Syensqo France SA have a generalized interest in the issues above.","lobbyists":[{"lobbyist":{"id":80986,"prefix":null,"prefix_display":null,"first_name":"DAVID","nickname":null,"middle_name":null,"last_name":"CETOLA","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":147477,"prefix":"mr","prefix_display":"MR.","first_name":"JAMES","nickname":null,"middle_name":"KA CHUN","last_name":"LAI","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":147511,"prefix":null,"prefix_display":null,"first_name":"IAN","nickname":null,"middle_name":null,"last_name":"CHOINIERE","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":116,"name":"Defense Advanced Research Projects Agency (DARPA)"},{"id":25,"name":"Defense, Dept of (DOD)"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"GOV","general_issue_code_display":"Government Issues","description":"Department of Justice's Advanced Notice of Proposed Rulemaking, Clarification and Modernization of Foreign Agents Registration Act (FARA) Implementing Regulations, including provisions related to the commercial exemption and the Lobbying Disclosure Act exemption. S. 4893, Lobbying Disclosure Improvement Act, including provisions related to LDA exemption disclosures.","foreign_entity_issues":"As parent entities of Syensqo USA LLC, Syensqo SA and Syensqo France SA have a generalized interest in the issues above.","lobbyists":[{"lobbyist":{"id":80986,"prefix":null,"prefix_display":null,"first_name":"DAVID","nickname":null,"middle_name":null,"last_name":"CETOLA","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":147477,"prefix":"mr","prefix_display":"MR.","first_name":"JAMES","nickname":null,"middle_name":"KA CHUN","last_name":"LAI","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":147511,"prefix":null,"prefix_display":null,"first_name":"IAN","nickname":null,"middle_name":null,"last_name":"CHOINIERE","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[]},{"general_issue_code":"TRD","general_issue_code_display":"Trade (domestic/foreign)","description":"USTR's s. 301 investigation of China and associated tariff actions, including imports of vanillin flavoring products, semiconductor manufacturing chemicals and battery-grade fluoropolymers. USTR, Docket Nos. USTR-2026-03868 (91 FR 9686), Request for Comments on the Design of a Plurilateral Agreement on Trade in Critical Minerals and Policy Actions To Strengthen the Resilience of Critical Mineral Supply Chains. Docket Nos. USTR-2026-0067 (91 FR 13394), Initiation of Section 301 Investigations: Acts, Policies, and Practices of Certain Economies Relating to Structural Excess Capacity and Production in Manufacturing Sectors. USTR, Docket Nos. USTR-2026-0133 (91 FR 12884), Initiation of Section 301 Investigations of Acts, Policies, and Practices of Various Economies Related to the Failure to Impose and Effectively Enforce a Prohibition on the Importation of Goods Produced with Forced Labor. U.S. Department of Commerce and U.S. International Trade Commission investigation into unfairly priced imports of vanillin. USTR's Request for Comments to Assist in Reviewing and Identifying Unfair Trade Practices and Initiating All Necessary Actions to Investigate Harm From Non-Reciprocal Trade Arrangements, USTR-2025-0001. White House Executive Order 14154 Unleashing American Energy, including provisions related to the necessity of unleashing American energy and securing supply chains. White House Executive Order No. 14156 Declaring a National Energy Emergency, including provisions related to the immediate risk of the current precariously inadequate and intermittent energy supply, and an increasingly unreliable grid. Executive Order 14257 of April 2, 2025 (Regulating Imports With a Reciprocal Tariff to Rectify Trade Practices that Contribute to Large and Persistent Annual United States Goods Trade Deficits). Executive Order 14346 of September 5, 2025 (Modifying the Scope of Reciprocal Tariffs and Establishing Procedures for Implementing Trade and Security Agreements). Department of Commerce Request for Public Comments on Section 232 National Security Investigation of Imports of Semiconductors and Semiconductor Manufacturing Equipment, 90 FR 15950 (Apr. 16, 2025). US International Trade Commission Investigation, No. 337-TA-1439, battery-grade PVDF. Department of Commerce Request for Public Comments on Section 232 National Security Investigation of Imports of Pharmaceuticals and Pharmaceutical Ingredients, 90 FR 15951 (Apr. 16, 2025). Department of Commerce Request for Public Comments on Section 232 National Security Investigation of Imports of Processed Critical Minerals and Derivative Products, 90 FR 17372 (Apr. 22, 2025). S. 3841, Last Sale Valuation Act of 2026, including provisions related to amending customs regulations concerning valuation of imports.","foreign_entity_issues":"As parent entities of Syensqo USA LLC, Syensqo SA and Syensqo France SA have a generalized interest in the issues above.","lobbyists":[{"lobbyist":{"id":80986,"prefix":null,"prefix_display":null,"first_name":"DAVID","nickname":null,"middle_name":null,"last_name":"CETOLA","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":147477,"prefix":"mr","prefix_display":"MR.","first_name":"JAMES","nickname":null,"middle_name":"KA CHUN","last_name":"LAI","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":147511,"prefix":null,"prefix_display":null,"first_name":"IAN","nickname":null,"middle_name":null,"last_name":"CHOINIERE","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":24,"name":"Commerce, Dept of (DOC)"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":1,"name":"SENATE"},{"id":41,"name":"Treasury, Dept of"},{"id":22,"name":"U.S. Trade Representative (USTR)"}]},{"general_issue_code":"RRR","general_issue_code_display":"Railroads","description":"Surface Transportation Board's Final Offer Rate Review (FORR).","foreign_entity_issues":"As parent entities of Syensqo USA LLC, Syensqo SA and Syensqo France SA have a generalized interest in the issues above.","lobbyists":[{"lobbyist":{"id":80986,"prefix":null,"prefix_display":null,"first_name":"DAVID","nickname":null,"middle_name":null,"last_name":"CETOLA","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":147477,"prefix":"mr","prefix_display":"MR.","first_name":"JAMES","nickname":null,"middle_name":"KA CHUN","last_name":"LAI","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":147511,"prefix":null,"prefix_display":null,"first_name":"IAN","nickname":null,"middle_name":null,"last_name":"CHOINIERE","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[]},{"general_issue_code":"ENG","general_issue_code_display":"Energy/Nuclear","description":"U.S. Department of Energy Qualifying Advanced Energy Project Credit (48C) Program. U.S. Department of Energy's Bipartisan Infrastructure Law Battery Materials Processing and Battery Manufacturing Funding Opportunity Announcement, DOE FOA-0002678 (May 2, 2022), including provisions related to the production of battery-grade materials.","foreign_entity_issues":"As parent entities of Syensqo USA LLC, Syensqo SA and Syensqo France SA have a generalized interest in the issues above.","lobbyists":[{"lobbyist":{"id":80986,"prefix":null,"prefix_display":null,"first_name":"DAVID","nickname":null,"middle_name":null,"last_name":"CETOLA","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":147477,"prefix":"mr","prefix_display":"MR.","first_name":"JAMES","nickname":null,"middle_name":"KA CHUN","last_name":"LAI","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":147511,"prefix":null,"prefix_display":null,"first_name":"IAN","nickname":null,"middle_name":null,"last_name":"CHOINIERE","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":24,"name":"Commerce, Dept of (DOC)"},{"id":25,"name":"Defense, Dept of (DOD)"},{"id":33,"name":"Energy, Dept of"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":1,"name":"SENATE"},{"id":39,"name":"State, Dept of (DOS)"}]},{"general_issue_code":"ENV","general_issue_code_display":"Environment/Superfund","description":"EPA's Advanced Notice of Proposed Rulemaking, Clean Water Act Effluent Limitations Guidelines and Standards for Organic Chemicals, Plastics and Synthetic Fibers Point Source Category. EPA's final rule on National Primary Drinking Water Regulation for six PFAS, including PFOA, PFOS, PFNA, HFPO-DA, PFHxS and PFBS. UN Global Plastics Treaty negotiations, including provisions related to chemical management reform initiatives. H.R. 6566, Recycling Technology Innovation Act, including provisions related to amendments to Section 129 of the Clean Air Act and classification of advanced recycling.","foreign_entity_issues":"As parent entities of Syensqo USA LLC, Syensqo SA and Syensqo France SA have a generalized interest in the issues above.","lobbyists":[{"lobbyist":{"id":80986,"prefix":null,"prefix_display":null,"first_name":"DAVID","nickname":null,"middle_name":null,"last_name":"CETOLA","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":147477,"prefix":"mr","prefix_display":"MR.","first_name":"JAMES","nickname":null,"middle_name":"KA CHUN","last_name":"LAI","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":147511,"prefix":null,"prefix_display":null,"first_name":"IAN","nickname":null,"middle_name":null,"last_name":"CHOINIERE","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":49,"name":"Environmental Protection Agency (EPA)"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"LBR","general_issue_code_display":"Labor Issues/Antitrust/Workplace","description":"H.R. 842, Protecting the Right to Organize Act, including provisions related to state Right to Work laws and union dues.","foreign_entity_issues":"As parent entities of Syensqo USA LLC, Syensqo SA and Syensqo France SA have a generalized interest in the issues above.","lobbyists":[{"lobbyist":{"id":80986,"prefix":null,"prefix_display":null,"first_name":"DAVID","nickname":null,"middle_name":null,"last_name":"CETOLA","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":147477,"prefix":"mr","prefix_display":"MR.","first_name":"JAMES","nickname":null,"middle_name":"KA CHUN","last_name":"LAI","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":147511,"prefix":null,"prefix_display":null,"first_name":"IAN","nickname":null,"middle_name":null,"last_name":"CHOINIERE","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[]},{"general_issue_code":"TAX","general_issue_code_display":"Taxation/Internal Revenue Code","description":"H.R. 1, One Big Beautiful Bill Act, including provisions related to clean energy tax credits and corporate tax modifications for US subsidiaries subject to foreign extraterritorial tax regimes. Department of Treasury's final regulations for the Section 30D New Clean Vehicle Credit (IRS-2023-0019) (Mar. 31, 2023), including provisions related to Critical Mineral and Battery Component Value Calculations, guidance on Foreign Entities of Concern prohibitions, and Department of Energy's final regulations on interpretation of Foreign Entity of Concern (DOE-2023-26513). Department of Treasury's final regulations for the Energy Security Tax Credits under Sections 48C and 45X (IRS-2022-0047) (Nov. 4, 2022), including provisions related to Critical Mineral and Battery Component Value Calculations, and guidance on Foreign Entities of Concern prohibitions. Department of Treasury, Internal Revenue Service's Guidance to Apply Interim Safe Harbors for Purposes of Determining a Taxpayers Material Assistance from a Prohibited Foreign Entity; Other Prohibited Foreign Entity Guidance (IRS Notice 2026-15). H.R. 591, Defending American Jobs and Investment Act, including provisions related to Undertaxed Profits Rule (UTPR), OECD Pillars I and II, and international tax provisions. H.R. 640, The Chemical Tax Repeal Act, including provisions related to repealing 2021 Superfund excise taxes.","foreign_entity_issues":"As parent entities of Syensqo USA LLC, Syensqo SA and Syensqo France SA have a generalized interest in the issues above.","lobbyists":[{"lobbyist":{"id":80986,"prefix":null,"prefix_display":null,"first_name":"DAVID","nickname":null,"middle_name":null,"last_name":"CETOLA","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":147477,"prefix":"mr","prefix_display":"MR.","first_name":"JAMES","nickname":null,"middle_name":"KA CHUN","last_name":"LAI","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":147511,"prefix":null,"prefix_display":null,"first_name":"IAN","nickname":null,"middle_name":null,"last_name":"CHOINIERE","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":24,"name":"Commerce, Dept of (DOC)"},{"id":25,"name":"Defense, Dept of (DOD)"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":1,"name":"SENATE"},{"id":41,"name":"Treasury, Dept of"},{"id":22,"name":"U.S. Trade Representative (USTR)"}]},{"general_issue_code":"MAN","general_issue_code_display":"Manufacturing","description":"S. 4585, CHIPS EQUIP Act, including provisions related to prohibiting covered entities that receive federal assistance relating to semiconductors from purchasing certain equipment from FEOCs. H.R.7037, Developing Overseas Mineral Investments and New Allied Networks for Critical Energies (DOMINANCE) Act, including provisions related to directing diplomatic efforts with partners to coordinate mining, processing, manufacturing, environmental and labor standards, and supply commitments. H.R. 7126, Secure Minerals Act, including provisions related to establishing a critical mineral reserve and supporting domestic mining, processing, recycling and repurposing critical minerals.","foreign_entity_issues":"As parent entities of Syensqo USA LLC, Syensqo SA and Syensqo France SA have a generalized interest in the issues above.","lobbyists":[{"lobbyist":{"id":80986,"prefix":null,"prefix_display":null,"first_name":"DAVID","nickname":null,"middle_name":null,"last_name":"CETOLA","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":147477,"prefix":"mr","prefix_display":"MR.","first_name":"JAMES","nickname":null,"middle_name":"KA CHUN","last_name":"LAI","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":147511,"prefix":null,"prefix_display":null,"first_name":"IAN","nickname":null,"middle_name":null,"last_name":"CHOINIERE","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":"HOM","general_issue_code_display":"Homeland Security","description":"Pub. 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Make America Healthy Again Commission report, dated Sep. 9, 2025, under Executive Order 14212 titled \"Establishing the President's Make America Healthy Again Commission,\" including provisions related to guidance on water contaminants and the generally recognized as safe (GRAS) process. Proposed rule from the U.S. Food and Drug Administration on Substances Generally Recognized as Safe.","foreign_entity_issues":"As parent entities of Syensqo USA LLC, Syensqo SA and Syensqo France SA have a generalized interest in the issues above.","lobbyists":[{"lobbyist":{"id":80986,"prefix":null,"prefix_display":null,"first_name":"DAVID","nickname":null,"middle_name":null,"last_name":"CETOLA","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":147477,"prefix":"mr","prefix_display":"MR.","first_name":"JAMES","nickname":null,"middle_name":"KA CHUN","last_name":"LAI","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":147511,"prefix":null,"prefix_display":null,"first_name":"IAN","nickname":null,"middle_name":null,"last_name":"CHOINIERE","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":135,"name":"Food & Drug Administration (FDA)"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":18,"name":"Office of Management & Budget (OMB)"},{"id":1,"name":"SENATE"}]}],"conviction_disclosures":[],"foreign_entities":[],"affiliated_organizations":[]},{"url":"https://lda.gov/api/v1/filings/9c34701c-f71d-4d65-81bc-130fe4e15d4b/","filing_uuid":"9c34701c-f71d-4d65-81bc-130fe4e15d4b","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/9c34701c-f71d-4d65-81bc-130fe4e15d4b/print/","filing_document_content_type":"text/html","income":null,"expenses":"350000.00","expenses_method":"A","expenses_method_display":"A","posted_by_name":"David Cetola","dt_posted":"2026-04-13T14:19:58-04:00","termination_date":null,"registrant_country":"United States of America","registrant_ppb_country":null,"registrant_address_1":"2564 US Highway 1","registrant_address_2":null,"registrant_different_address":true,"registrant_city":"Lawrence","registrant_state":"NJ","registrant_zip":"08648","registrant":{"id":400408933,"url":"https://lda.gov/api/v1/registrants/400408933/","house_registrant_id":null,"name":"SYENSQO USA LLC","description":"Solvay manufactures an extensive range of chemicals and plastics such as soda ash, etc.","address_1":"2564 US Highway 1","address_2":null,"address_3":null,"address_4":null,"city":"Lawrence","state":"NJ","state_display":"New Jersey","zip":"08648","country":"US","country_display":"United States of America","ppb_country":"US","ppb_country_display":"United States of America","contact_name":"DAVE CETOLA","contact_telephone":"+1 609-819-5900","dt_updated":"2026-07-02T20:03:19.523398-04:00"},"client":{"id":190355,"url":"https://lda.gov/api/v1/clients/190355/","client_id":12,"name":"SYENSQO USA LLC","general_description":null,"client_government_entity":false,"client_self_select":true,"state":"TX","state_display":"Texas","country":"US","country_display":"United States of America","ppb_state":"TX","ppb_state_display":"Texas","ppb_country":"US","ppb_country_display":"United States of America","effective_date":"2009-03-17"},"lobbying_activities":[{"general_issue_code":"AER","general_issue_code_display":"Aerospace","description":"H.R. 3838, S. 2296, National Defense Authorization Act for Fiscal Year 2026, including provisions related to the procurement of aircraft. Potential bill for National Defense Authorization for Fiscal Year 2027, including provisions related to the procurement of aircraft, and appropriations for civil, space and defense aerospace platforms and associated materials in the aviation supply chain.","foreign_entity_issues":"As parent entities of Syensqo USA LLC, Syensqo SA and Syensqo France SA have a generalized interest in the issues above.","lobbyists":[{"lobbyist":{"id":80986,"prefix":null,"prefix_display":null,"first_name":"DAVID","nickname":null,"middle_name":null,"last_name":"CETOLA","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":147477,"prefix":"mr","prefix_display":"MR.","first_name":"JAMES","nickname":null,"middle_name":"KA CHUN","last_name":"LAI","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":147511,"prefix":null,"prefix_display":null,"first_name":"IAN","nickname":null,"middle_name":null,"last_name":"CHOINIERE","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"}]},{"general_issue_code":"AUT","general_issue_code_display":"Automotive Industry","description":"Potential legislation that would incentivize recognizing advanced recycling and utilizing circular plastics in the automotive supply chain.","foreign_entity_issues":"As parent entities of Syensqo USA LLC, Syensqo SA and Syensqo France SA have a generalized interest in the issues above.","lobbyists":[{"lobbyist":{"id":80986,"prefix":null,"prefix_display":null,"first_name":"DAVID","nickname":null,"middle_name":null,"last_name":"CETOLA","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":147477,"prefix":"mr","prefix_display":"MR.","first_name":"JAMES","nickname":null,"middle_name":"KA CHUN","last_name":"LAI","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":147511,"prefix":null,"prefix_display":null,"first_name":"IAN","nickname":null,"middle_name":null,"last_name":"CHOINIERE","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[]},{"general_issue_code":"AVI","general_issue_code_display":"Aviation/Airlines/Airports","description":"H.R. 3838, S. 2296, National Defense Authorization Act for Fiscal Year 2026, including provisions related to the procurement of aircraft. Technology export license governed by U.S. Department of Commerce Bureau of Industry and Security's Export Administration Regulations. Potential bill for National Defense Authorization for Fiscal Year 2027, including provisions related to the procurement of aircraft, and appropriations for civil, space and defense aerospace platforms and associated materials in the aviation supply chain.","foreign_entity_issues":"As parent entities of Syensqo USA LLC, Syensqo SA and Syensqo France SA have a generalized interest in the issues above.","lobbyists":[{"lobbyist":{"id":80986,"prefix":null,"prefix_display":null,"first_name":"DAVID","nickname":null,"middle_name":null,"last_name":"CETOLA","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":147477,"prefix":"mr","prefix_display":"MR.","first_name":"JAMES","nickname":null,"middle_name":"KA CHUN","last_name":"LAI","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":147511,"prefix":null,"prefix_display":null,"first_name":"IAN","nickname":null,"middle_name":null,"last_name":"CHOINIERE","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":24,"name":"Commerce, Dept of (DOC)"},{"id":116,"name":"Defense Advanced Research Projects Agency (DARPA)"},{"id":25,"name":"Defense, Dept of (DOD)"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"TAR","general_issue_code_display":"Tariff (miscellaneous tariff bills)","description":"Potential House and Senate legislation related to the renewal of Miscellaneous Tariff Bill and Generalized System of Preferences.","foreign_entity_issues":"As parent entities of Syensqo USA LLC, Syensqo SA and Syensqo France SA have a generalized interest in the issues above.","lobbyists":[{"lobbyist":{"id":80986,"prefix":null,"prefix_display":null,"first_name":"DAVID","nickname":null,"middle_name":null,"last_name":"CETOLA","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":147477,"prefix":"mr","prefix_display":"MR.","first_name":"JAMES","nickname":null,"middle_name":"KA CHUN","last_name":"LAI","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":147511,"prefix":null,"prefix_display":null,"first_name":"IAN","nickname":null,"middle_name":null,"last_name":"CHOINIERE","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[]},{"general_issue_code":"CHM","general_issue_code_display":"Chemicals/Chemical Industry","description":"H.R. 3838, S. 2296, National Defense Authorization Act for Fiscal Year 2026, including provisions related to the regulation of PFAS and CERCLA liability waivers. Potential bills for National Defense Authorization for Fiscal Year 2027, including provisions related to the regulation of PFAS and CERCLA liability waivers. Discussion Draft of Legislation to Modernize the Toxic Substances Control Act, including provisions related to updating EPA's TSCA review process. H.R. 1267, Water Systems PFAS Liability Protection Act, including provisions related to CERCLA exemptions for PFAS liability. H.R. 1415, S. 623, No IRIS Act, including provisions related to the use of assessments generated by the IRIS program. Potential Senate legislation directing EPA to regulate PFAS in certain sectors and environmental media, and exemptions to CERCLA liability. Potential Senate legislation to reform TSCA Section 5 requirements for significant new use notices. EPA's Advanced Notice of Proposed Rulemaking, Clean Water Act Effluent Limitations Guidelines and Standards for Organic Chemicals, Plastics and Synthetic Fibers Point Source Category. EPA's Rule on TSCA 8(a)(7) Reporting and Recordkeeping Requirements for PFAS Substances. EPA's New Chemical Review process under TSCA, including the process to approve new chemicals, low volume and polymer exemptions from TSCA's pre-manufacture notice requirements. EPA's final rule on National Primary Drinking Water Regulation for six PFAS, including PFOA, PFOS, PFNA, HFPO-DA, PFHxS and PFBS. EPA's final rule on designations of PFAS as CERCLA Hazardous Substances. EPA's proposed Toxic Substances Control Act risk management rule for Trichloroethylene (TCE), EPA-HQ-OPPT-2020-0642-0026, 88 Fed. Reg. 74,712 (Oct. 31, 2023). EPA's proposed rule on Procedures for Chemical Risk Evaluation under the Toxic Substances Control Act, EPA-HQ-OPPT-2023-0496, 88 Fed. Reg. 74,292 (Oct. 30, 2023). EPA's final revised risk determination for 1,4-dioxane under the Toxic Substances Control Act, EPA-HQ-OPPT-2016-0723, 89 Fed. Reg. 89,993 (Nov. 14, 2024). EPA's draft scope of the risk evaluation for vinyl chloride under the Toxic Substances Control Act, EPA-HQ-OPPT-2018-0448, 90 Fed. Reg. 4,738 (Jan. 16, 2025). EPA Pesticides Registration, Product code DV 5-26762 (Actizone), Reg. No. 4564-27.","foreign_entity_issues":"As parent entities of Syensqo USA LLC, Syensqo SA and Syensqo France SA have a generalized interest in the issues above.","lobbyists":[{"lobbyist":{"id":80986,"prefix":null,"prefix_display":null,"first_name":"DAVID","nickname":null,"middle_name":null,"last_name":"CETOLA","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":147477,"prefix":"mr","prefix_display":"MR.","first_name":"JAMES","nickname":null,"middle_name":"KA CHUN","last_name":"LAI","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":147511,"prefix":null,"prefix_display":null,"first_name":"IAN","nickname":null,"middle_name":null,"last_name":"CHOINIERE","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":24,"name":"Commerce, Dept of (DOC)"},{"id":25,"name":"Defense, Dept of (DOD)"},{"id":49,"name":"Environmental Protection Agency (EPA)"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"DEF","general_issue_code_display":"Defense","description":"Department of Defense's Defense Production Act Title III program and Industrial Base Analysis and Sustainment (IBAS) program, including funding for projects that support national security. H.R. 3838, S. 2296, National Defense Authorization Act for Fiscal Year 2026, including provisions related to the support for the defense industrial base, reporting on uses of PFAS that are critical to national security. S. 4212, Prioritizing the Warfighter in Defense Contracting Act of 2026, including provisions related to prohibiting stock buybacks, dividends and caps compensation as a condition of contracting with the Department of Defense. Department of Defense Appropriations Act, 2027, including provisions related to national security projects under the Industrial Base Analysis and Sustainment (IBAS) program. Department of Defense Appropriations Act, 2026, including provisions related to national security projects under the Industrial Base Analysis and Sustainment (IBAS) program.","foreign_entity_issues":"As parent entities of Syensqo USA LLC, Syensqo SA and Syensqo France SA have a generalized interest in the issues above.","lobbyists":[{"lobbyist":{"id":80986,"prefix":null,"prefix_display":null,"first_name":"DAVID","nickname":null,"middle_name":null,"last_name":"CETOLA","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":147477,"prefix":"mr","prefix_display":"MR.","first_name":"JAMES","nickname":null,"middle_name":"KA CHUN","last_name":"LAI","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":147511,"prefix":null,"prefix_display":null,"first_name":"IAN","nickname":null,"middle_name":null,"last_name":"CHOINIERE","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":116,"name":"Defense Advanced Research Projects Agency (DARPA)"},{"id":25,"name":"Defense, Dept of (DOD)"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"GOV","general_issue_code_display":"Government Issues","description":"Department of Justice's Advanced Notice of Proposed Rulemaking, Clarification and Modernization of Foreign Agents Registration Act (FARA) Implementing Regulations, including provisions related to the commercial exemption and the Lobbying Disclosure Act exemption. S. 4893, Lobbying Disclosure Improvement Act, including provisions related to LDA exemption disclosures.","foreign_entity_issues":"As parent entities of Syensqo USA LLC, Syensqo SA and Syensqo France SA have a generalized interest in the issues above.","lobbyists":[{"lobbyist":{"id":80986,"prefix":null,"prefix_display":null,"first_name":"DAVID","nickname":null,"middle_name":null,"last_name":"CETOLA","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":147477,"prefix":"mr","prefix_display":"MR.","first_name":"JAMES","nickname":null,"middle_name":"KA CHUN","last_name":"LAI","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":147511,"prefix":null,"prefix_display":null,"first_name":"IAN","nickname":null,"middle_name":null,"last_name":"CHOINIERE","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[]},{"general_issue_code":"TRD","general_issue_code_display":"Trade (domestic/foreign)","description":"USTR's s. 301 investigation of China and associated tariff actions, including imports of vanillin flavoring products, semiconductor manufacturing chemicals and battery-grade fluoropolymers. USTR, Docket Nos. USTR-2026-03868 (91 FR 9686), Request for Comments on the Design of a Plurilateral Agreement on Trade in Critical Minerals and Policy Actions To Strengthen the Resilience of Critical Mineral Supply Chains. Docket Nos. USTR-2026-0067 (91 FR 13394), Initiation of Section 301 Investigations: Acts, Policies, and Practices of Certain Economies Relating to Structural Excess Capacity and Production in Manufacturing Sectors. USTR, Docket Nos. USTR-2026-0133 (91 FR 12884), Initiation of Section 301 Investigations of Acts, Policies, and Practices of Various Economies Related to the Failure to Impose and Effectively Enforce a Prohibition on the Importation of Goods Produced with Forced Labor. U.S. Department of Commerce and U.S. International Trade Commission investigation into unfairly priced imports of vanillin. USTR's Request for Comments to Assist in Reviewing and Identifying Unfair Trade Practices and Initiating All Necessary Actions to Investigate Harm From Non-Reciprocal Trade Arrangements, USTR-2025-0001. White House Executive Order 14154 Unleashing American Energy, including provisions related to the necessity of unleashing American energy and securing supply chains. White House Executive Order No. 14156 Declaring a National Energy Emergency, including provisions related to the immediate risk of the current precariously inadequate and intermittent energy supply, and an increasingly unreliable grid. Executive Order 14257 of April 2, 2025 (Regulating Imports With a Reciprocal Tariff to Rectify Trade Practices that Contribute to Large and Persistent Annual United States Goods Trade Deficits). Executive Order 14346 of September 5, 2025 (Modifying the Scope of Reciprocal Tariffs and Establishing Procedures for Implementing Trade and Security Agreements). Department of Commerce Request for Public Comments on Section 232 National Security Investigation of Imports of Semiconductors and Semiconductor Manufacturing Equipment, 90 FR 15950 (Apr. 16, 2025). US International Trade Commission Investigation, No. 337-TA-1439, battery-grade PVDF. Department of Commerce Request for Public Comments on Section 232 National Security Investigation of Imports of Pharmaceuticals and Pharmaceutical Ingredients, 90 FR 15951 (Apr. 16, 2025). Department of Commerce Request for Public Comments on Section 232 National Security Investigation of Imports of Processed Critical Minerals and Derivative Products, 90 FR 17372 (Apr. 22, 2025). S. 3841, Last Sale Valuation Act of 2026, including provisions related to amending customs regulations concerning valuation of imports.","foreign_entity_issues":"As parent entities of Syensqo USA LLC, Syensqo SA and Syensqo France SA have a generalized interest in the issues above.","lobbyists":[{"lobbyist":{"id":80986,"prefix":null,"prefix_display":null,"first_name":"DAVID","nickname":null,"middle_name":null,"last_name":"CETOLA","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":147477,"prefix":"mr","prefix_display":"MR.","first_name":"JAMES","nickname":null,"middle_name":"KA CHUN","last_name":"LAI","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":147511,"prefix":null,"prefix_display":null,"first_name":"IAN","nickname":null,"middle_name":null,"last_name":"CHOINIERE","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":24,"name":"Commerce, Dept of (DOC)"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":1,"name":"SENATE"},{"id":41,"name":"Treasury, Dept of"},{"id":22,"name":"U.S. Trade Representative (USTR)"}]},{"general_issue_code":"RRR","general_issue_code_display":"Railroads","description":"Surface Transportation Board's Final Offer Rate Review (FORR).","foreign_entity_issues":"As parent entities of Syensqo USA LLC, Syensqo SA and Syensqo France SA have a generalized interest in the issues above.","lobbyists":[{"lobbyist":{"id":80986,"prefix":null,"prefix_display":null,"first_name":"DAVID","nickname":null,"middle_name":null,"last_name":"CETOLA","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":147477,"prefix":"mr","prefix_display":"MR.","first_name":"JAMES","nickname":null,"middle_name":"KA CHUN","last_name":"LAI","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":147511,"prefix":null,"prefix_display":null,"first_name":"IAN","nickname":null,"middle_name":null,"last_name":"CHOINIERE","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[]},{"general_issue_code":"ENG","general_issue_code_display":"Energy/Nuclear","description":"U.S. Department of Energy Qualifying Advanced Energy Project Credit (48C) Program. 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Legislation to amend the Bank Holding Company Act of 1956 to strike or alter section 2(c)(2)(H) of such act. Regulatory activity impacting financial services providers, as defined by section 1002(26) of the Dodd-Frank Act. FDIC proposed regulations impacting Industrial Banks and Parent Companies. Issues relating to Consumer Financial Protection Bureau enforcement actions against federal contractors. 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These measures include advancing flexibilities for the use of telehealth, extending premium tax credits in the individual health insurance market, and reauthorizing and funding the National Health Service Corps and the Teaching Health Center Graduate Medical Education programs. We urged Congress to advance PBM reform legislation, reform prior authorization in Medicare Advantage plans. Expand Patient Access and Telehealth: We urged Congress to reintroduce and pass the Chronic Care Management Improvement Act. This legislation would have removed the cost sharing requirement for patients to access chronic care management services. We also support allowing the physician that performs chronic care management services to waive the requirement that the patient pay the 20 percent coinsurance fee associated with this service. Supported extending Pandemic-related telehealth flexibilities in the Continuing Resolution that passed Congress. Supported S. 1261, Connect for Health Act of 2025, to expand telehealth services under Medicare, by removing certain geographic restrictions starting October 1, 2025. Also supported H.R. 1899, Audio-Only Telehealth Access Act of 2025, to modify payment rules for certain covered medical items and services. We also supported the Protecting Rural Telehealth Access Act, a bill that would ensure that seniors may continue to access audio-only telehealth consults with their physician after this option expired in 2024. We supported the Preserving Telehealth, Hospital, and Ambulance Access Act, which would extend these flexibilities for two years until the end of 2026. We urged Congress to protect the public health infrastructure, recognize evidence-based science and preserve healthcare agency staffing to inform and protect the public from infectious disease and other health emergencies. Incidences of previously well-controlled, vaccine-preventable diseases, such as pertussis (whooping cough) and measles, are increasing in the United States. Vaccines are vital to our ability to prevent diseases that threaten public health, including novel diseases and future pandemics. We urged Congress to utilize the best possible scientific evidence to guide public health legislation. It is critical that public health leaders support evidence-based medicine, including the use of vaccines and other effective public health strategies that protect the public. ACP conducted a Hill Briefing on using scientifically driven, evidenced-based vaccines. Medicare Payments to Physicians: Met with House Doctors Caucus about Medicare payment reform, including draft language to be included in bills for a Medicare Economic Index inflationary updated to the physician fee schedule for physician practices. Supported and urged Congress to pass H.R. 8163, the Provider Reimbursement Stability Act, to enhance Medicare reimbursement stability for physicians by modernizing the Medicare Physician Fee Schedule. ACP focused on countering Surgeons on MPFS Final Rule Efficiency Adjustment -action alert and lobbying outreach. Extensive advocacy support for 2.5% reduction in the intra-service portion of practice expense for efficiency adjustment in Centers for Medicare and Medicaid Services 2026 final fee schedule rule. Primary care is excluded from adjustment. Support Value-Based Care: Urged reintroduction and support of the Value in Health Care Act of 2024. The bill provides a multi-year commitment to reforming care delivery by extending MACRAs 5 percent advanced alternative payment models (APM) incentives that expired at the end of 2024. ACP supported the Preserving Patient Access to Accountable Care Act which aligns with Colleges policy to support the transition to value-based payments through alternative payment models (APMs) that can accommodate a wide range of specialties, practice sizes, and unique patient populations. ACP supported this legislation as it would extend the incentive payments for qualifying physicians and other clinicians to participate in Medicare advanced APMs through payment year 2027 at an increased amount of 3.53 percent and would freeze the scheduled increase in qualifying thresholds. Pricing Transparency/Consolidation: Supported reintroducing and passing the Lower Costs, More Transparency Act, which are consistent with our policy and would improve access to and affordability of health care for patients. This legislation required disclosure of changes in hospital or health facility ownership to reveal when private equity firms acquire hospitals, larger physician practices or nursing homes, promoted price transparency among hospitals, health plans and pharmacy benefit managers and promoted site neutrality for Medicare and Medicare beneficiaries. We supported the Consolidated Appropriations Act, 2026 (CAA) (H.R. 7148), signed into law on February 3, 2026, that provides comprehensive funding for federal agencies through September 30, 2026. This legislation included PBM reforms. The reforms center on rebate pass‑through, increased transparency, standardized reporting, and expanded federal oversight. The Affordable Care Act (ACA) (P.L. 111-148, P.L. 111-152): Urged legislation to extend permanently the premium tax subsidies afforded under the ACA. Supported legislation by Senators Jeanne Shaheen and Tammy Baldwin, along with U.S. Congresswoman Lauren Underwood, the Health Care Affordability Act-bicameral legislation making permanent the ACAs enhanced premium tax credits for Marketplace coverage as extended through the Inflation Reduction Act. The law provides consumers with subsidies (premium tax credits) that lower costs for households with incomes between 100 percent and 400 percent of the federal poverty level (FPL). It expands the Medicaid program to cover all adults with income below 138 percent of the FPL. Urged Congress to include an extension of premium tax credits in OBBB. Urged Congress to include the enhanced PTCs in the CAA. FY2026 Appropriations/Agency Restructuring: Urged Congress to support funding for the Centers for Disease Control and Prevention's programs in the FY 2026 Labor, Health and Human Services, Education and Related Agencies Appropriations bill as well as funding shared evenly between the U.S. Centers for Disease Control and Prevention (CDC) and the National Institutes of Health (NIH) to conduct public health research into firearm morbidity and mortality prevention. Advocated for funding for the Health Resources Services Administration (HRSA); Title Vi, Section 747, Primary Care Training and Enhancement (PCTE), Health Resources and Services Administration (HRSA); National Health Service Corps (NHSC); Agency for Healthcare Research and Quality (AHRQ); the Centers for Disease Control and Prevention's (CDC) Office on Smoking and Health (OSH). Urged Congress to include report language in the FY2026 Labor HHS appropriations bill to direct the GAO to conduct a study encompassing the last decade of CMS estimates of new and revised code utilizations. ACP believes CMS has overestimated utilizations, thus adversely affecting available funds in the Medicare physician fee schedule for other code usage. While the House and Senate bills included language, we prefer the stronger House version language and hope Congress will pass the FY26 Labor HHS bills. Also urged Congress to include report language in the FY2027 Labor HHS appropriations bill directing a study on extent G2211 add on codes and increases in fee schedule for primary care are being retained by hiring entities (hospitals, ACOs, private equity) versus the physicians. Supported S.Res.343, Recognizing the Important Work of the United States Preventive Task Force (USPTF). This resolution highlights the important role of the USPTF in making evidence-based recommendations about health promotion and the effectiveness of preventive health services and urges HHS to ensure current members on the task force serve their four-year terms to completion. Also sent a letter to House and Senate leadership urging the protection of the integrity of the United States Preventive Services Task Force (USPSTF), supported by the Agency for Healthcare Research and Quality (AHRQ). Primary Care and the Physician Workforce: Urged Congress to support the Resident Physician Shortage Reduction Act of 2025 (S. 2439/ H.R. 4731), which would increase the number of Medicare supported direct graduate medical education (DGME) and indirect medical education (IME) positions by 14,000 over seven years. ACP supported the Conrad State 30 and Physician Access Reauthorization Act, S. 709 and H.R. 1585, to allow states to sponsor foreign-trained physicians to work in medically underserved areas in exchange for a waiver of the physicians' two-year foreign residence requirement. We supported the Resident Education Deferred Interest (REDI) Act (S 942/HR 2028) that, if passed, will allow borrowers to qualify for interest-free deferment on their student loans while serving in a medical or dental internship or residency program. We supported the reauthorization and funding increases included for the Teaching Health Center Graduate Medical Education program, Community Health Center program and National Health Service Corps in the Continuing Resolution that was extended by Congress to September 30, 2025, and urged Congress for funding beyond the current extension. We urged Congress to note the success and importance of the Public Service Loan Forgiveness (PSLF) program and urged its preservation. Congress recognized the importance of recruiting and retaining highly qualified public service professionals when it enacted PSLF with bipartisan support. Supported legislation for the H-1Bs for Physicians and Healthcare Workforce Act, H.R. 7961. The bill's primary goal is to exempt healthcare professionals from a $100,000 H-1B visa filing fee. Prescription Drug Reform: Supported the Capping Prescription Costs Act, introduced by Senator Raphael Warnock. The legislation would lower prescription drug costs for millions of Americans by placing annual caps on out-of-pocket costs for prescription drugs at $2,000 for individuals and $4,000 for families with private insurance. Supported bipartisan Drug-price Transparency for Consumers (DTC) Act, a bill that would require price disclosures on advertisements for prescription drugs in order to empower patients and reduce Americans colossal spending on medications. The bill was introduced by Senators Dick Durbin and Chuck Grassley. ACP also supported the Saving Seniors Money on Prescriptions Act, H.R. 950, which aims to drive down the rising costs of prescription drugs for patients on Medicare by improving price transparency in Pharmacy Benefit Managers (PBMs) business practices. Urged Congress to reintroduce and pass: 1) the Lowering Drug Costs for American Families Act, to expand the number of prescription drugs which Medicare can negotiate under the Inflation Reduction Act from 20 to 50 starting in 2029; 2) the Medicare PBM Accountability Act, legislation aimed at lowering the costs of prescription drugs for seniors covered by Medicare Part D and Medicare Advantage plans; 3) the Increasing Access to Biosimilars Act of 2023, legislation which would encourage adoption of biosimilars in Medicare and improve biosimilar accessibility, by establishing a new pilot program - a voluntary, shared savings demonstration program - for providers of biosimilars in Medicare Part B; 4) the Cutting Copays Act, legislation which would eliminate cost-sharing for generic drugs for LIS beneficiaries, helping to incentivize the use of generic drugs; and the Drug Shortage Prevention Act of 2023, which would require that manufacturers of over-the-counter and prescription drugs notify Food & Drug Administration when they are unlikely to meet demand. ACP supported legislation, Drug-price Transparency for Consumers (DTC) Act, by Senators. Durbin and Grassley that requires Direct-to-Consumer advertisements for prescription drugs and biological products paid for by Medicare and Medicaid to include the list price or Wholesale Acquisition Cost (WAC) for a 30-month supply-which is the price set by manufacturers (and which is paid by uninsured patients, as well as the 50 percent of patients with high-deductible plans). ACP opposed H.R. 238, the Healthy Technology Act of 2025 (HTA). That Act would amend current law to clarify that artificial intelligence (AI) and machine learning technologies can qualify as a practitioner eligible to prescribe drugs if authorized by the state involved and approved, cleared, or authorized by the Food and Drug Administration. Family Caregiving: ACP supported the Family Caregiver Awareness, Resources, and Education (CARE) Partnerships Act, introduced by Rep. Dingell. This legislation would promote the health and well-being of family caregivers - those who provide the majority of long-term services and support (LTSS) in the United States - so that they can maintain their own health and their ability to continue providing essential care to patients who require LTSS. Administrative Burden: Urged Congress to reintroduce and pass the Improving Seniors' Timely Access to Care Act. This bipartisan legislation nearly passed last Congress and would reduce burdens associated with prior authorization in Medicare Advantage (MA) by: l) protecting beneficiaries from any disruptions in care due to prior authorization requirements as they transition between MA plans; 2) requiring all MA plans adopt electronic prior authorization capabilities to streamline the process for prior authorization approval; and 3) standardizing the process and procedures for reporting electronic prior authorization criteria to MA plans. Scope of Practice: Opposed the Equitable Community Access to Pharmacist Services Act, which would expand Medicare coverage to permanently include select services provided by a pharmacist. Clinical Labs: Supported the provision in H.R. 6366 that would delay payment reductions and data reporting periods for the Clinical Laboratory Fee Schedule under the Protecting Access to Medicare Act (PAMA). Legislation could improve patient access to laboratory tests used to diagnose, monitor, prevent, and manage diseases for Medicare beneficiaries. Cures 2.0: Reviewed and supported Cures 2.0 legislation.","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":37837,"prefix":null,"prefix_display":null,"first_name":"BRIAN","nickname":null,"middle_name":null,"last_name":"BUCKLEY","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":60177,"prefix":null,"prefix_display":null,"first_name":"JARED","nickname":null,"middle_name":null,"last_name":"FROST","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":40417,"prefix":null,"prefix_display":null,"first_name":"SHUAN","nickname":null,"middle_name":null,"last_name":"TOMLINSON","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":104508,"prefix":null,"prefix_display":null,"first_name":"GEORGE","nickname":null,"middle_name":null,"last_name":"LYONS","suffix":"jr","suffix_display":"JR"},"covered_position":null,"new":false},{"lobbyist":{"id":150464,"prefix":null,"prefix_display":null,"first_name":"KORY","nickname":null,"middle_name":null,"last_name":"STUER","suffix":null,"suffix_display":null},"covered_position":null,"new":true}],"government_entities":[{"id":134,"name":"Centers For Disease Control & Prevention (CDC)"},{"id":136,"name":"Centers For Medicare and Medicaid Services (CMS)"},{"id":135,"name":"Food & Drug Administration (FDA)"},{"id":34,"name":"Health & Human Services, Dept of (HHS)"},{"id":201,"name":"Homeland Security, Dept of (DHS)"},{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":9,"name":"President of the U.S."},{"id":1,"name":"SENATE"},{"id":39,"name":"State, Dept of (DOS)"},{"id":42,"name":"Veterans Affairs, Dept of (VA)"}]}],"conviction_disclosures":[],"foreign_entities":[],"affiliated_organizations":[]},{"url":"https://lda.gov/api/v1/filings/d99ce340-6f20-4710-8ecc-fdd1165dfd9d/","filing_uuid":"d99ce340-6f20-4710-8ecc-fdd1165dfd9d","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/d99ce340-6f20-4710-8ecc-fdd1165dfd9d/print/","filing_document_content_type":"text/html","income":null,"expenses":"85668.00","expenses_method":"B","expenses_method_display":"B","posted_by_name":"Shari Erickson","dt_posted":"2026-04-14T11:47:59-04:00","termination_date":null,"registrant_country":"United States of America","registrant_ppb_country":null,"registrant_address_1":"25 Massachusetts Avenue, NW, Suite 700","registrant_address_2":null,"registrant_different_address":false,"registrant_city":"WASHINGTON","registrant_state":"DC","registrant_zip":"20001","registrant":{"id":2002,"url":"https://lda.gov/api/v1/registrants/2002/","house_registrant_id":32190,"name":"AMERICAN COLLEGE OF PHYSICIANS","description":null,"address_1":"25 Massachusetts Avenue, NW, Suite 700","address_2":null,"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":"GEORGE LYONS JR.","contact_telephone":"+1 202-261-4531","dt_updated":"2026-07-13T17:53:37.650943-04:00"},"client":{"id":102673,"url":"https://lda.gov/api/v1/clients/102673/","client_id":12,"name":"AMERICAN COLLEGE OF PHYSICIANS","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":"1996-02-14"},"lobbying_activities":[{"general_issue_code":"HCR","general_issue_code_display":"Health Issues","description":"ACPs 2026 First Quarter Lobbying Disclosure Report Senate Finance Committee Hearing: ACP advocated that Congress enacts FY2026 appropriations bills for funding Labor-HHS and several other federal agencies. These measures include advancing flexibilities for the use of telehealth, extending premium tax credits in the individual health insurance market, and reauthorizing and funding the National Health Service Corps and the Teaching Health Center Graduate Medical Education programs. We urged Congress to advance PBM reform legislation, reform prior authorization in Medicare Advantage plans. Expand Patient Access and Telehealth: We urged Congress to reintroduce and pass the Chronic Care Management Improvement Act. This legislation would have removed the cost sharing requirement for patients to access chronic care management services. We also support allowing the physician that performs chronic care management services to waive the requirement that the patient pay the 20 percent coinsurance fee associated with this service. Supported extending Pandemic-related telehealth flexibilities in the Continuing Resolution that passed Congress. Supported S. 1261, Connect for Health Act of 2025, to expand telehealth services under Medicare, by removing certain geographic restrictions starting October 1, 2025. Also supported H.R. 1899, Audio-Only Telehealth Access Act of 2025, to modify payment rules for certain covered medical items and services. We also supported the Protecting Rural Telehealth Access Act, a bill that would ensure that seniors may continue to access audio-only telehealth consults with their physician after this option expired in 2024. We supported the Preserving Telehealth, Hospital, and Ambulance Access Act, which would extend these flexibilities for two years until the end of 2026. We urged Congress to protect the public health infrastructure, recognize evidence-based science and preserve healthcare agency staffing to inform and protect the public from infectious disease and other health emergencies. Incidences of previously well-controlled, vaccine-preventable diseases, such as pertussis (whooping cough) and measles, are increasing in the United States. Vaccines are vital to our ability to prevent diseases that threaten public health, including novel diseases and future pandemics. We urged Congress to utilize the best possible scientific evidence to guide public health legislation. It is critical that public health leaders support evidence-based medicine, including the use of vaccines and other effective public health strategies that protect the public. ACP conducted a Hill Briefing on using scientifically driven, evidenced-based vaccines. Medicare Payments to Physicians: Met with House Doctors Caucus about Medicare payment reform, including draft language to be included in bills for a Medicare Economic Index inflationary updated to the physician fee schedule for physician practices. Supported and urged Congress to pass H.R. 8163, the Provider Reimbursement Stability Act, to enhance Medicare reimbursement stability for physicians by modernizing the Medicare Physician Fee Schedule. ACP focused on countering Surgeons on MPFS Final Rule Efficiency Adjustment -action alert and lobbying outreach. Extensive advocacy support for 2.5% reduction in the intra-service portion of practice expense for efficiency adjustment in Centers for Medicare and Medicaid Services 2026 final fee schedule rule. Primary care is excluded from adjustment. Support Value-Based Care: Urged reintroduction and support of the Value in Health Care Act of 2024. The bill provides a multi-year commitment to reforming care delivery by extending MACRAs 5 percent advanced alternative payment models (APM) incentives that expired at the end of 2024. ACP supported the Preserving Patient Access to Accountable Care Act which aligns with Colleges policy to support the transition to value-based payments through alternative payment models (APMs) that can accommodate a wide range of specialties, practice sizes, and unique patient populations. ACP supported this legislation as it would extend the incentive payments for qualifying physicians and other clinicians to participate in Medicare advanced APMs through payment year 2027 at an increased amount of 3.53 percent and would freeze the scheduled increase in qualifying thresholds. Pricing Transparency/Consolidation: Supported reintroducing and passing the Lower Costs, More Transparency Act, which are consistent with our policy and would improve access to and affordability of health care for patients. This legislation required disclosure of changes in hospital or health facility ownership to reveal when private equity firms acquire hospitals, larger physician practices or nursing homes, promoted price transparency among hospitals, health plans and pharmacy benefit managers and promoted site neutrality for Medicare and Medicare beneficiaries. We supported the Consolidated Appropriations Act, 2026 (CAA) (H.R. 7148), signed into law on February 3, 2026, that provides comprehensive funding for federal agencies through September 30, 2026. This legislation included PBM reforms. The reforms center on rebate pass‑through, increased transparency, standardized reporting, and expanded federal oversight. The Affordable Care Act (ACA) (P.L. 111-148, P.L. 111-152): Urged legislation to extend permanently the premium tax subsidies afforded under the ACA. Supported legislation by Senators Jeanne Shaheen and Tammy Baldwin, along with U.S. Congresswoman Lauren Underwood, the Health Care Affordability Act-bicameral legislation making permanent the ACAs enhanced premium tax credits for Marketplace coverage as extended through the Inflation Reduction Act. The law provides consumers with subsidies (premium tax credits) that lower costs for households with incomes between 100 percent and 400 percent of the federal poverty level (FPL). It expands the Medicaid program to cover all adults with income below 138 percent of the FPL. Urged Congress to include an extension of premium tax credits in OBBB. Urged Congress to include the enhanced PTCs in the CAA. FY2026 Appropriations/Agency Restructuring: Urged Congress to support funding for the Centers for Disease Control and Prevention's programs in the FY 2026 Labor, Health and Human Services, Education and Related Agencies Appropriations bill as well as funding shared evenly between the U.S. Centers for Disease Control and Prevention (CDC) and the National Institutes of Health (NIH) to conduct public health research into firearm morbidity and mortality prevention. Advocated for funding for the Health Resources Services Administration (HRSA); Title Vi, Section 747, Primary Care Training and Enhancement (PCTE), Health Resources and Services Administration (HRSA); National Health Service Corps (NHSC); Agency for Healthcare Research and Quality (AHRQ); the Centers for Disease Control and Prevention's (CDC) Office on Smoking and Health (OSH). Urged Congress to include report language in the FY2026 Labor HHS appropriations bill to direct the GAO to conduct a study encompassing the last decade of CMS estimates of new and revised code utilizations. ACP believes CMS has overestimated utilizations, thus adversely affecting available funds in the Medicare physician fee schedule for other code usage. While the House and Senate bills included language, we prefer the stronger House version language and hope Congress will pass the FY26 Labor HHS bills. Also urged Congress to include report language in the FY2027 Labor HHS appropriations bill directing a study on extent G2211 add on codes and increases in fee schedule for primary care are being retained by hiring entities (hospitals, ACOs, private equity) versus the physicians. Supported S.Res.343, Recognizing the Important Work of the United States Preventive Task Force (USPTF). This resolution highlights the important role of the USPTF in making evidence-based recommendations about health promotion and the effectiveness of preventive health services and urges HHS to ensure current members on the task force serve their four-year terms to completion. Also sent a letter to House and Senate leadership urging the protection of the integrity of the United States Preventive Services Task Force (USPSTF), supported by the Agency for Healthcare Research and Quality (AHRQ). Primary Care and the Physician Workforce: Urged Congress to support the Resident Physician Shortage Reduction Act of 2025 (S. 2439/ H.R. 4731), which would increase the number of Medicare supported direct graduate medical education (DGME) and indirect medical education (IME) positions by 14,000 over seven years. ACP supported the Conrad State 30 and Physician Access Reauthorization Act, S. 709 and H.R. 1585, to allow states to sponsor foreign-trained physicians to work in medically underserved areas in exchange for a waiver of the physicians' two-year foreign residence requirement. We supported the Resident Education Deferred Interest (REDI) Act (S 942/HR 2028) that, if passed, will allow borrowers to qualify for interest-free deferment on their student loans while serving in a medical or dental internship or residency program. We supported the reauthorization and funding increases included for the Teaching Health Center Graduate Medical Education program, Community Health Center program and National Health Service Corps in the Continuing Resolution that was extended by Congress to September 30, 2025, and urged Congress for funding beyond the current extension. We urged Congress to note the success and importance of the Public Service Loan Forgiveness (PSLF) program and urged its preservation. Congress recognized the importance of recruiting and retaining highly qualified public service professionals when it enacted PSLF with bipartisan support. Supported legislation for the H-1Bs for Physicians and Healthcare Workforce Act, H.R. 7961. The bill's primary goal is to exempt healthcare professionals from a $100,000 H-1B visa filing fee. Prescription Drug Reform: Supported the Capping Prescription Costs Act, introduced by Senator Raphael Warnock. The legislation would lower prescription drug costs for millions of Americans by placing annual caps on out-of-pocket costs for prescription drugs at $2,000 for individuals and $4,000 for families with private insurance. Supported bipartisan Drug-price Transparency for Consumers (DTC) Act, a bill that would require price disclosures on advertisements for prescription drugs in order to empower patients and reduce Americans colossal spending on medications. The bill was introduced by Senators Dick Durbin and Chuck Grassley. ACP also supported the Saving Seniors Money on Prescriptions Act, H.R. 950, which aims to drive down the rising costs of prescription drugs for patients on Medicare by improving price transparency in Pharmacy Benefit Managers (PBMs) business practices. Urged Congress to reintroduce and pass: 1) the Lowering Drug Costs for American Families Act, to expand the number of prescription drugs which Medicare can negotiate under the Inflation Reduction Act from 20 to 50 starting in 2029; 2) the Medicare PBM Accountability Act, legislation aimed at lowering the costs of prescription drugs for seniors covered by Medicare Part D and Medicare Advantage plans; 3) the Increasing Access to Biosimilars Act of 2023, legislation which would encourage adoption of biosimilars in Medicare and improve biosimilar accessibility, by establishing a new pilot program - a voluntary, shared savings demonstration program - for providers of biosimilars in Medicare Part B; 4) the Cutting Copays Act, legislation which would eliminate cost-sharing for generic drugs for LIS beneficiaries, helping to incentivize the use of generic drugs; and the Drug Shortage Prevention Act of 2023, which would require that manufacturers of over-the-counter and prescription drugs notify Food & Drug Administration when they are unlikely to meet demand. ACP supported legislation, Drug-price Transparency for Consumers (DTC) Act, by Senators. Durbin and Grassley that requires Direct-to-Consumer advertisements for prescription drugs and biological products paid for by Medicare and Medicaid to include the list price or Wholesale Acquisition Cost (WAC) for a 30-month supply-which is the price set by manufacturers (and which is paid by uninsured patients, as well as the 50 percent of patients with high-deductible plans). ACP opposed H.R. 238, the Healthy Technology Act of 2025 (HTA). That Act would amend current law to clarify that artificial intelligence (AI) and machine learning technologies can qualify as a practitioner eligible to prescribe drugs if authorized by the state involved and approved, cleared, or authorized by the Food and Drug Administration. Family Caregiving: ACP supported the Family Caregiver Awareness, Resources, and Education (CARE) Partnerships Act, introduced by Rep. Dingell. This legislation would promote the health and well-being of family caregivers - those who provide the majority of long-term services and support (LTSS) in the United States - so that they can maintain their own health and their ability to continue providing essential care to patients who require LTSS. Administrative Burden: Urged Congress to reintroduce and pass the Improving Seniors' Timely Access to Care Act. This bipartisan legislation nearly passed last Congress and would reduce burdens associated with prior authorization in Medicare Advantage (MA) by: l) protecting beneficiaries from any disruptions in care due to prior authorization requirements as they transition between MA plans; 2) requiring all MA plans adopt electronic prior authorization capabilities to streamline the process for prior authorization approval; and 3) standardizing the process and procedures for reporting electronic prior authorization criteria to MA plans. Scope of Practice: Opposed the Equitable Community Access to Pharmacist Services Act, which would expand Medicare coverage to permanently include select services provided by a pharmacist. Clinical Labs: Supported the provision in H.R. 6366 that would delay payment reductions and data reporting periods for the Clinical Laboratory Fee Schedule under the Protecting Access to Medicare Act (PAMA). Legislation could improve patient access to laboratory tests used to diagnose, monitor, prevent, and manage diseases for Medicare beneficiaries. 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S. 2512, A bill to amend the Internal Revenue Code of 1986 to provide a credit for re-enrollment provisions in retirement plans of small employers (118th Congress). H.R.7293, Automatic IRA Act of 2024 (118th Congress). S. 1707, Helping Young Americans Save for Retirement Act. S. 1831, Auto Reenroll Act. H.R. 2696/S. 1526, Retirement Savings for Americans Act. H.R. 2023/S. 988, Women's Retirement Protection Act. H.R. 2544/S. 1222, Financial Freedom Act. H.R. 2869, EBSA Investigations Transparency Act. H.R. 2958, Balance the Scales Act. H.R. 1, to provide for reconciliation pursuant to title II of H. Con. Res. 14. S. 2210, Unlocking Benefits for Independent Workers Act. S. 2217, Independent Retirement Fairness Act. S. 2228, Modern Worker Empowerment Act. S. 2335, Pensions for All Act. S. 2003, Strengthening Benefit Plans Act. H.R. 6722, Automatic IRA Act. H.R. 6084, ERISA Litigation Reform Act. H.R. 5169/S. 2403, Retire through Ownership Act. S. 1728, Employee Ownership Representation Act. H.R. 9765/S. 5148, Improving Retirement Security for Family Caregivers Act. (118th Congress) H.R. 9764/S. 5149, Catching Up Family Caregivers Act. (118th Congress) H.R.7362, Form 5500 Filing Simplification Act.","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":41060,"prefix":null,"prefix_display":null,"first_name":"KENT","nickname":null,"middle_name":"A","last_name":"MASON","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":55177,"prefix":null,"prefix_display":null,"first_name":"MICHAEL","nickname":null,"middle_name":"L","last_name":"HADLEY","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":62920,"prefix":null,"prefix_display":null,"first_name":"CHRIS","nickname":null,"middle_name":"L","last_name":"GASTON","suffix":null,"suffix_display":null},"covered_position":"Chief of Staff, Rep. Rush Holt","new":false},{"lobbyist":{"id":117138,"prefix":null,"prefix_display":null,"first_name":"ROBERT","nickname":null,"middle_name":"B","last_name":"DAVIS","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":139258,"prefix":"mr","prefix_display":"MR.","first_name":"ADAM","nickname":null,"middle_name":null,"last_name":"MCMAHON","suffix":null,"suffix_display":null},"covered_position":null,"new":true}],"government_entities":[{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":85,"name":"Pension Benefit Guaranty Corporation (PBGC)"},{"id":165,"name":"Pension & Welfare Benefits Administration"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"TAX","general_issue_code_display":"Taxation/Internal Revenue Code","description":"Proposals related to retirement plan enhancements. Proposals relating to defined benefit plans, including plan funding and multiemployer plan issues. Issues related to nonqualified deferred compensation. Proposals related to PEP service crediting. Proposals related to Section 401(h) surplus and VEBA surplus. Issues related to Internal Revenue Code Section 162(m). Issues related to tax incentives for retirement savings. Proposals related to environmental, social, and governance plan investments and proxy voting. Issues related to Qualified Professional Asset Managers. Issues related to cybersecurity in retirement plans. Proposals related to PBGC premiums. Proposals related to retirement target date funds. Issues related to the Department of Labor's proposed regulation defining fiduciary for investment advice purposes. Proposals and regulations related to cash balance, pension equity, and other hybrid pension plans. Proposals related to electronic disclosure of information under ERISA, the Internal Revenue Code, and securities law. Issues related to Form 5500 filing and missing participants. Issues related to the use of brokerage windows in defined contribution plans. Proposals regarding pension risk transfers. Proposals to modify required minimum distribution rules. Proposals that would modify limits on retirement plan contributions. State-administered retirement plan initiatives. Annuitization with respect to defined contribution plans. Proposals that would consolidate various retirement and IRA types. Proposals regarding a retirement lost and found. Proposals related to savings accounts for emergencies. Issues related to paid family and medical leave. Issues regarding age 18 eligibility. Issues related to Roth catch-up contribution effective date. Issues related to Department of Labor's use of common interest agreements. Proposals related to retirement plan litigation. Proposals regarding retirement plan investments in private assets. Proposals regarding an annuity safe harbor. Proposals regarding the use of pension surplus assets. Proposals regarding remittance tax. Advisory Opinion on lifetime income. Issues related to PTE 1977-4. Issues related to 502(g). Proposals relating to qualified charitable distributions. Issues relating to the Department of Labor's proposed rule \"Fiduciary Duties in Selecting Designated Investment Alternatives.\" H.R. 3596, Rightsizing Pension Premiums Act (115th Congress). H.R. 4830, Pension and Budget Integrity Act (117th Congress). H.R. 5877/S. 3746, Pension Risk Transfer Accountability Act (117th Congress). H.R. 7310, Protecting Americas Retirement Security Act (117th Congress). S. 4219/H.R. 7740, Employee and Retiree Access to Justice Act (117th Congress). H.R. 7780, Mental Health Matters Act (117th Congress). Technical corrections of H.R. 2617, Consolidated Appropriations Act of 2023, SECURE 2.0 Act of 2022 (117th Congress). S. 2512, A bill to amend the Internal Revenue Code of 1986 to provide a credit for re-enrollment provisions in retirement plans of small employers (118th Congress). H.R.7293, Automatic IRA Act of 2024 (118th Congress). S. 1707, Helping Young Americans Save for Retirement Act. S. 1831, Auto Reenroll Act. H.R. 2696/S. 1526, Retirement Savings for Americans Act. H.R. 2023/S. 988, Women's Retirement Protection Act. H.R. 2544/S. 1222, Financial Freedom Act. H.R. 2869, EBSA Investigations Transparency Act. H.R. 2958, Balance the Scales Act. H.R. 1, to provide for reconciliation pursuant to title II of H. Con. Res. 14. S. 2210, Unlocking Benefits for Independent Workers Act. S. 2217, Independent Retirement Fairness Act. S. 2228, Modern Worker Empowerment Act. S. 2335, Pensions for All Act. S. 2003, Strengthening Benefit Plans Act. H.R. 6722, Automatic IRA Act. H.R. 6084, ERISA Litigation Reform Act. H.R. 5169/S. 2403, Retire through Ownership Act. S. 1728, Employee Ownership Representation Act. H.R. 9765/S. 5148, Improving Retirement Security for Family Caregivers Act. (118th Congress) H.R. 9764/S. 5149, Catching Up Family Caregivers Act. (118th Congress) H.R.7362, Form 5500 Filing Simplification Act.","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":41060,"prefix":null,"prefix_display":null,"first_name":"KENT","nickname":null,"middle_name":"A","last_name":"MASON","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":55177,"prefix":null,"prefix_display":null,"first_name":"MICHAEL","nickname":null,"middle_name":"L","last_name":"HADLEY","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":62920,"prefix":null,"prefix_display":null,"first_name":"CHRIS","nickname":null,"middle_name":"L","last_name":"GASTON","suffix":null,"suffix_display":null},"covered_position":"Chief of Staff, Rep. Rush Holt","new":false},{"lobbyist":{"id":117138,"prefix":null,"prefix_display":null,"first_name":"ROBERT","nickname":null,"middle_name":"B","last_name":"DAVIS","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":139258,"prefix":"mr","prefix_display":"MR.","first_name":"ADAM","nickname":null,"middle_name":null,"last_name":"MCMAHON","suffix":null,"suffix_display":null},"covered_position":null,"new":true}],"government_entities":[{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":85,"name":"Pension Benefit Guaranty Corporation (PBGC)"},{"id":1,"name":"SENATE"}]},{"general_issue_code":"FIN","general_issue_code_display":"Financial Institutions/Investments/Securities","description":"Proposals related to 403(b) plan investments. Issues related to Rule 180. H.R. 1013/S. 424, Retirement Fairness for Charities and Educational Institutions Act. S. 5139, Empowering Main Street in America Act (118th Congress). H.R. 2799, Expanding Access to Capital Act (118th Congress). Technical corrections of H.R. 2617, Consolidated Appropriations Act of 2023, SECURE 2.0 Act of 2022 (117th Congress). H.R. 3383, Incentivizing New Ventures and Economic Strength Through Capital Formation Act","foreign_entity_issues":"","lobbyists":[{"lobbyist":{"id":41060,"prefix":null,"prefix_display":null,"first_name":"KENT","nickname":null,"middle_name":"A","last_name":"MASON","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":55177,"prefix":null,"prefix_display":null,"first_name":"MICHAEL","nickname":null,"middle_name":"L","last_name":"HADLEY","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":62920,"prefix":null,"prefix_display":null,"first_name":"CHRIS","nickname":null,"middle_name":"L","last_name":"GASTON","suffix":null,"suffix_display":null},"covered_position":"Chief of Staff, Rep. Rush Holt","new":false},{"lobbyist":{"id":117138,"prefix":null,"prefix_display":null,"first_name":"ROBERT","nickname":null,"middle_name":"B","last_name":"DAVIS","suffix":null,"suffix_display":null},"covered_position":null,"new":false},{"lobbyist":{"id":139258,"prefix":"mr","prefix_display":"MR.","first_name":"ADAM","nickname":null,"middle_name":null,"last_name":"MCMAHON","suffix":null,"suffix_display":null},"covered_position":null,"new":false}],"government_entities":[{"id":2,"name":"HOUSE OF REPRESENTATIVES"},{"id":88,"name":"Securities & Exchange Commission (SEC)"},{"id":1,"name":"SENATE"}]}],"conviction_disclosures":[],"foreign_entities":[],"affiliated_organizations":[]}]}