lobbying_activities: 1809595
Data license: Public Domain (U.S. Government data) · Data source: Federal Register API & Regulations.gov API
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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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| 1809595 | d72d6b8a-cf8a-4ae9-8b1b-860c40c431dc | Q1 | COMMUNITY BANKERS ASSOCIATION OF ILLINOIS | 400531588 | COMMUNITY BANKERS ASSOCIATION OF ILLINOIS | 2016 | first_quarter | BAN | Community Bankers Association of Illinois (CBAI) 2015 Federal Policy Priorities (House and Senate, FDIC, OCC, CFPB) 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. Credit Union Taxation and Expansion of Powers - Credit unions now indistinguishable from community banks, grown to control a significant share of the banking services market. Original business model now outdated. Credit unions strayed from founding purpose of serving individuals of modest means and with a common bond. Same financial services as community banks. Federal tax-exempt status, in exchange for serving their original mission is no longer justified. Credit unions paying their fair share of income taxes. Credit unions adhering to a common bond or operating within a well-defined local community, neighborhood or rural district . Credit unions similarity to other types of mutually owned financial institutions - savings banks (SB) and savings and loans (S&L). The exemption for SBs and S&Ls repealed by Congress in 1951 - (reason) - active competition with taxable institutions [community banks]. The Office of Management and Budget tax expenditure analysis - tax-exemption for credit unions result in loss of tax revenues of $9.46 billion over fiscal years 2014-2018. Credit union expansion of commercial lending powers - increasing the percentage of cap on member business lending (MBL). Loan growth at the expense of tax-paying community banks. Fundamental altering the exclusive member-focused character of credit unions - a condition for their original tax exemption. Applying Community Reinvestment Act (CRA) requirements to credit unions - same asset size distinction as banks and thrifts. The same Call Report filing requirements for credit unions as those imposed on community banks. Tax subsidy and level the playing field between credit unions and tax-paying community banks. Farm Credit System - Expansionist agenda of the Farm Credit System (FCS). FCS almost the equivalent of commercial banks yet retaining the benefits of Government Sponsored Enterprise (GSE) status. Tax advantages - unfair competitive advantage. Follow narrow historic mission - abolish or be subject to taxation and oversight and regulation. Narrow founding purpose of the System to serve bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives. Support and cooperation of Farm Credit Administration (FCA) - FCS straying beyond its original mission and scope and engaging in inappropriate and unprecedented lending activities. FCS significant systemic and taxpayer bail-out risks. The FCS (only GSE) in active competition with community banks. Public sector (multi-billion dollar GSE) competition with the private sector (Main Street community banks). Funding and tax benefits impact on community banks. FCS not following its narrow historical mission. Follow narrow mission or abolish System. Abolished or taxation when exceeding a given asset threshold, lending to large borrowers, or engaging in non-farm lending activity. FCS requirement to engage in joint rulemaking with federal banking agencies, a member of a federal banking agency on its three person board, requirement to register a class of stock with the Securities and Exchange Commission (SEC), full disclosure as required by the SEC Act, publication of instances of illegal lending and exemptions granted, and subject to regulatory safeguards, disclosures and controls equal to community banks and housing GSEs, including CFPB oversight. Congress convening joint committee hearings to investigate the operations, supervision, risks and financial soundness of the FCS, and impact on rural community banks. Enhanced Cyber, Data and Payment Card Security - Establish a federal data security standard and notice requirement for all entities that store consumer data comparable to the Gramm-Leach-Bliley Act (GLBA) standards that apply to community banks. Shifting the liability for all costs associated with the data breach - including fraud losses and the cost of card reissuance - to the party that caused the breach. Legislation - H.R. 4500 - Community Bank Reporting Relief Act (amends the FDIC Act to permit reduced reporting requirements (Call Reports) for the first and third quarters for highly-rated well-capitalized banks (All Sections) (House) H.R. 1188 -The Credit Union Business Job Creation Act (expand credit union member business lending cap) (All sections) (House and Senate, FDIC, OCC, CFPB) H.R. 1233 and S. 812 - CLEAR Relief Act of 2015 (tiered regulatory reform and relief for community banks) (All sections) (House and Senate, FDIC, OCC, CFPB) 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, FDIC, OCC, CFPB) Comment Letters - Comment letter - Financial Crimes Enforcement Network (FinCEN), (Regulatory Impact Assessment & Initial Flexibility Analysis - Customer Due Diligence Requirements for Financial Institutions, RIN 1506-AB25 - breakeven analysis of new regulations, clarify and strengthen customer due diligence (CDD) requirements regarding beneficial owners of legal entity customers) (House) Comment Letter - National Credit Union Associations (NCUA) (proposed expansion of field of membership in their Notice of Proposed Rulemaking - Field of Membership - RIN 3133-AE31) Comment Letter - Federal Reserve, FDIC, OCC (Economic Growth and Recovery Paperwork Reduction Act (EGRPRA decennial regulatory review process) - specifically Bank Secrecy Act (BSA)/Anti-Money Laundering (AML), Community Reinvestment Act (CRA), repeat examination findings, brokered deposits (Call Report and waivers), and FR Y-8 reporting (as contained in CBAI Comment Letters - Docket ID FFIEC-2014-0001 and Docket No. R-1510) (House) Action Alerts - Action Alert - National Credit Union Associations (NCUA) proposed expansion of field of membership in their Notice of Proposed Rulemaking - Field of Membership - RIN 3133-AE31 (NCUA, House and Senate) Miscellaneous - Regarding the Financial Accounting Standards Board (FASB) Current Expected Credit Loss (CECL) model - specifically the proposed new methodology impact on community banks, day-one estimates of losses, estimated loss adjustments throughout the life of the loan, operating system changes, recognition of losses sooner in the life cycle of a loan, and countercyclical additions to the Allowance for Loan and Lease Losses (House and Senate, FDIC, OCC, CFPB) Regarding the Financial Accounting Standards Board (FASB) Current Expected Credit Loss (CECL) model - specifically U.S. House of Representatives Tipton-Murphy member letter to FASB (House) | Consumer Financial Protection Bureau (CFPB),Consumer Product Safety Commission (CPSC),Federal Deposit Insurance Corporation (FDIC),Federal Reserve System,Financial Crimes Enforcement Network (FinCEN),HOUSE OF REPRESENTATIVES,Natl Credit Union Administration (NCUA),Office of the Comptroller of the Currency (OCC),SENATE | 50000 | 0 | 0 | 2016-04-16T15:35:02.047000-04:00 |