lobbying_activities: 1736580
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| id | filing_uuid | filing_type | registrant_name | registrant_id | client_name | filing_year | filing_period | issue_code | specific_issues | government_entities | income_amount | expense_amount | is_no_activity | is_termination | received_date |
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| 1736580 | cdf6282a-2351-43dd-a4ae-df5a9b46efce | Q3 | COMMUNITY BANKERS ASSOCIATION OF ILLINOIS | 400531588 | COMMUNITY BANKERS ASSOCIATION OF ILLINOIS | 2015 | third_quarter | CSP | Community Bankers Association of Illinois (CBAI) 2015 Federal Policy Priorities (House and Senate) Tiered Regulation and Supervision for Community Banks - The Independent Community Bankers of Americas Plan for Prosperity- Outsized risks taken by Wall Street mega banks during the financial crisis. The different/modest risks posed by community banks. Regulations not reflecting those differences. Regulatory burden on community banks by a one-size-fits-all approach. Disproportionate burden of banking laws and regulations on community banks. Credit unions, Farm Credit System lenders and other non-bank financial service providers not subject to the same laws and regulations as community banks. Unlevel playing field and a significant competitive disadvantage for community banks. Independent Community Bankers of Americas (ICBA) Plan for Prosperity - a regulatory platform - community banks able to thrive and contribute to local economies. Excessive, redundant and costly regulations. Regulatory accountability. Community banks dedicating resources to promoting economic growth. Steady increase in regulations over many decades. Regulatory threats to community banks and their communities. The Plan for Prosperity regarding: Basel III original intent. additional capital for small holding companies - modernize the Federal Reserves Policy Statement. Securities and Exchange Commission rules. reforming mortgage lending. accountability in bank exams by providing an appeals process. bank oversight and examinations - targeting risks. annual requirement for redundant privacy notices. consumer regulation - inclusive and accountable CFPB governance. arbitrary disparate impact fair lending causes of action. viability of mutual banks with new charter options. cost-benefit analysis to justify new rules. red tape in small business lending - burdensome data collection. community bank mortgage servicing. Treasury Assistant Secretary for Community Banks. subchapter S constraints. five-year loss carryback - support for lending during economic downturns. risk targeting in the Volcker Rule. Tiered regulatory system based on size and risk profile - banking law, rule, and regulation clearly distinguishing and appropriately regulating community banks. Consumer Financial Protection Bureau Mortgage Lending and Housing Finance Reform - Imprudent mortgage lending contribution to the mortgage meltdown and the financial crisis. Community banks common sense relationship lending and not participate in abusive and predatory lending practices. Community banks thriving on the strength of their reputations and incentive to make fair and reasonable loans. No need for prescriptive regulations to compel community banks to do the right thing for their customers. Curb imprudent lending practices. Not impacting responsible community bank loan products designed to meet the diverse needs of their customers, including borrowers with special needs and circumstances, first-time homebuyers, borrowers in rural and underserved areas, and low-to-moderate income borrowers. Regulators recognition of the difference between the non-traditional lending practiced by community banks and predatory lending practiced by others. Community bank loans held in portfolio for the life of the loan, including balloon payment loans, in all geographic areas should receive automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs). Special accommodations for small creditors, flexibility in serving the needs of customers and communities, particularly in rural areas, and the definition of underserved areas to include economically challenged areas. Reforms to the housing GSEs to include the existence of an impartial secondary market for residential mortgages, one that is financially strong and reliable, the need for some government tie to the secondary market to ensure the continued flow of credit and market liquidity during severe economic stress, no limit to full participation by community banks, and a return of private capital. Additional reforms to include community banks access to sell loans through an independent entity; no appropriation of community bank customer data for the purpose of cross selling financial services; maintain the Federal Home Loan Banks as a community bank access point (but not the only access point) to the national secondary market; pricing of any governmental guaranty fair and equal to all participants regardless of volume of loans guaranteed; and no further consolidation of the housing finance system. Stop aggressively compelling community banks to repurchase transferred real estate mortgages for technical violations of underwriting agreements that had no bearing on the quality of the loan at the time of underwriting. Disparate Impact Fair Lending Causes of Action - Enforcement actions by the Department of Housing and Urban Development (HUD) and the Department of Justice (DOJ) - disparate impact. Additional obligation on community banks to consider such factors as race or national origin in credit decisions, which is specifically precluded by law - untenable situation. Consumer Financial Protection Bureau Reform - Community banks regulatory relief to serve unique needs of their customers and not hinder new product development and innovation. Community bank flexibility to meet the unique needs of customers and community banks additional and unnecessary regulatory requirements to prevent their serving their communities. No a one-size-fits-all approach to CFPB regulations. Community banks not enduring any additional consumer regulatory burden on top of the existing regulatory burden. Single-Director governance of the CFPB versus a five-member commission. Prudential regulators participating with the CFPB in the rule-writing process. The Financial Stability Oversight Council (FSOC) power to veto CFPB rules. Broad definition of firms that grant credit being subject to the CFPB rules, and their robust supervision and examinations. Focus of any enhanced regulation of financial products on unregulated shadow financial companies. CFPBs efforts to use its authority to address non-banks, such as Wal-Mart, serving as channels for financial products. CFPB holding mega banks and financial firms up to the existing standards for compliance with consumer laws, rules and regulations as required by community banks. Federal Home Loan Bank System - The Federal Home Loan Banks (FHLBs) partnership with community banks - short-term liquidity, long-term funding and other financial products and providing lendable funds for the local communities. Maintaining the regional structure, special functions and purposes of the FHLBs. The FHLB Systems health, stability and reliability for its members. FHFAs proposed (2014) revisions to FHLB membership eligibility requirements - impact on the FHLB System and its members including, but not limited to, regulatory burden, member balance sheet management, stability of the System, and continued reliability as a funding partner, future value of FHLB membership and the implications for membership decisions; and impact on housing and community development throughout the System. The proposed rule is also contrary to the will of Congress. FHLB System reliance as the sole aggregator or securitizer of residential mortgages for community banks, and the FHFAs imposition of an ongoing housing mission asset test on community financial institutions. Excessive Intervention in Monetary Policy - The sustained record-low zero interest rate policy (ZIRP) - disproportionate impact on community banks, senior citizens and discourages savings. Record-low interest rates for five years+ does not constitute temporary intervention but long-term and harmful manipulation. The limits to what Fed monetary policy can accomplish, especially given major offsetting negative effects. Legislation - H.R. 1233 and S. 812 - CLEAR Relief Act of 2015 (tiered regulatory reform and relief for community banks) (All sections) (House and Senate) H.R. 2205 and S. 961 - Data Security Act of 2015 (data breach and security, notifications, safeguards, GLBA compliance procedures) (All sections) (House and Senate) Comment Letters - Comment Letter - CFPB, grace period for enforcement and liability in the implementation, and delay in the implementation of the TRID Action Alerts - H.R. 1233 and S. 812 - Community Lending Enhancement and Regulatory (CLEAR) Relief Act of 2015 (community bank regulatory relief) (all sections) (House and Senate), and H.R. 1523 and S. 1816 - Community Bank Access to Capital (enhance community bank and thrift access to capital) (all sections) (House and Senate) Miscellaneous - Regarding CFPB, delay in implementation of TRID and period of restrained enforcement and liability, the definition of rural and underserved areas in the QM, regulatory burden on community banks, declining number of community banks and community bank consolidation (House) | Consumer Financial Protection Bureau (CFPB),Federal Deposit Insurance Corporation (FDIC),Federal Housing Finance Agency (FHFA),HOUSE OF REPRESENTATIVES,Labor, Dept of (DOL),Natl Credit Union Administration (NCUA),SENATE | 50000 | 0 | 0 | 2015-10-18T12:39:23.270000-04:00 |