lobbying_activities: 1987691
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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| 1987691 | 3af4b364-88d7-4be4-b44c-f5717e8ca955 | Q2 | COMMUNITY BANKERS ASSOCIATION OF ILLINOIS | 400531588 | COMMUNITY BANKERS ASSOCIATION OF ILLINOIS | 2017 | second_quarter | FIN | Regulatory relief for community banks in the 115th Congress Tiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity The ICBAs Plan for Prosperity contains the following issue areas and recommendations. Access to Capital Restore the original intent of the Basel III rule Create a more accurate identification of systemic risk Spur additional capital for small bank holding companies by modernizing the Federal Reserves policy statement Relieve community banks from excessive Securities and Exchange Commission rules Repeal the Collins Amendment for non-SIFIs Address minority bank capital challenges Regulatory Relief Balance consumer regulation through more accountable Consumer Financial Protection Bureau governance Eliminate arbitrary disparate impact fair lending lawsuits Ensure the viability of mutual banks through new charter and capital options Support rigorous cost-benefit analyses of all new rules to determine if they are justified and indeed needed Modernize the Bank Secrecy Act (BSA) Cut the red tape in small business lending by eliminating burdensome data collection Target the Volker Rule on a banks individual risk Preserve access to investment advice for middle-class savers Mortgage Reform Create a safe harbor from onerous underwriting standards Establish relief from burdensome HMDA, escrow and appraisal requirements Preserve the ability for community banks to continue servicing mortgage loans Reform the closing process and accompanying paperwork Bank Oversight and Examination Strengthen accountability in bank exams and create a workable appeals process Reform bank oversight and examination to better target risk Tax Relief Lower marginal rates needed for individuals, corporations and businesses Incentivize credit for low- and middle-income customers and American agriculture Modernize Subchapter S constraints Create limited liability corporation (LLC) option for community banks Repeal the estate tax Update the bank qualified (BQ) bond issuer limitation Support a five-year loss carryback that encourages lending during economic downturns Create a tax credit for Bank Secrecy Act (BSA) compliance costs Agriculture and Rural America Address arbitrary agricultural loan concentration limits Institute tax relief for rural lending (House, Senate) CBAI 2017 Federal Policy Priorities Meaningful regulatory relief, together with tiered regulation and supervision for community banks, as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity - See above. Regarding the implementation of regulatory initiatives - Special purpose fintech national bank charters by the OCC to financial technology companies Financial Accounting Standards Board (FASB) Current Expected Credit Loss Model (CECL) Consumer Financial Protection Bureaus (CFPB) proposed payday and vehicle title (small-dollar credit) lending rules De novo bank formation, the dual banking system, and charter choice The issue of too-big-to-fail banks and financial firms - protect our financial system, economy and taxpayers from future bailouts - Credible proposals to address TBTF and reduce the risks the mega banks poses to the financial system, economy and American taxpayers including those from: FDIC Vice Chairman Thomas Hoenig, Minneapolis Federal Reserve Chairman Neel Kashkari and Arthur Wilmarth - George Washington University Law School professor and a nationally recognized authority on bank regulation. These plans are in addition to a number of legislative proposals including a 21st century version of the original 1933 Glass-Steagall [separation of banking and commerce] Act. New Farm Bill and abolishing (or reigning-in) the Farm Credit System, crop insurance, USDA loan guarantee programs - volume caps and additional funding - Expansionist agenda of the Farm Credit System (FCS), the benefits of their Government Sponsored Enterprise (GSE) status, funding and tax advantages of the FCS, direct competition with community banks, cheerleader regulator - Farm Credit Administration (FCA), blatant discrimination against rural community banks, following its narrow historic mission of serving bona fide farmers, ranchers, young-beginning farmers, small farmers, and their farmer-owned cooperatives, Joint House/Senate hearings, abolish or subject FCS to funding restrictions, taxation and rigorous oversight and regulation. Taxation of credit unions and their expansion of powers - Outdated original business model, straying from their founding mission, ignoring field of membership or common bond requirement, now provide the same financial services as community banks, expansionist agenda, cheerleader regulator - National Credit Union Administration, justification for federal tax-exempt status, blatant discrimination against tax-paying community banks, eliminate subsidies or pay fair share of income taxes. Enhanced data, cyber and payment card security (data security) - Wide-scale data security breaches at national retail chain stores and other entities, far-reaching and costly incidents resulting in reissuing credit and debit cards at a considerable cost. Community banks defense against cyber security threats, their role in securing data and personal information as a matter of good business practice and to comply with legal and regulatory requirements. Data security principals include the cost of data breaches borne by that party that caused the breach, all participants should be subject to verifiable Gramm-Leach-Bliley Act-like data security standards, a national data security breach and notification standard should replace the current patchwork of state laws, and any new data security standard proposals should ensure that community banks are not burdened with having to reassess existing critical systems, and implement and comply with new regulations. Community banks reliance on third party service providers (core data processors and subcontractors of technology service providers for example), broadening the regulatory supervision of these service providers to ensure they comply with nondisclosure and confidentiality requirements similar to existing requirements for community banks. Mortgage lending and housing finance reform - Community banks strength of their reputation, incentive to make fair and reasonable loans, and do not need prescriptive regulations to compel them to do what is right for their customers Community bank loans held in portfolio receiving automatic Qualified Mortgage (QM) status and an automatic exemption from escrow requirements for Higher-Priced Mortgage Loans (HPMLs), increase in the small servicer exemption, increase in HMDA reporting levels, a safe harbor from the newly implemented TRID, accommodations for community banks to provide greater flexibility in serving the needs of their customers and communities, (particularly in rural areas, and urges expanding the definition of underserved areas to include economically challenged areas), use of property evaluations completed by qualified bank staff in lieu of a residential property appraisal for any residential mortgage that a community bank originates and retains in its portfolio. Regarding the reform of the housing GSEs, the continued existence of an impartial secondary market for residential mortgages that is financially strong and reliable, some level of government involvement in the secondary market to ensure the continued flow of credit and market liquidity during periods of severe economic stress, reform that does not limit the full participation by community banks or disrupts the housing market, encouraging a return of private capital to reduce the reliance on government funding and help protect taxpayers from another bailout, sale of loans through an independent entity that does not compete with community banks, no appropriation of community bank customer data for the purpose of cross selling financial services, the Federal Home Loan Banks preserved as a community bank access point (but not the only access point) to the national secondary market, the pricing of any governmental guaranty fair and equal to all participants regardless of volume of loans guaranteed, the 30-year fixed-rate mortgage for creditworthy customers in all markets, no further consolidation of the housing finance system that would result in mega banks and financial firms dominating the market. Consumer Financial Protection Bureau Reform - The Consumer Financial Protection Bureau (CFPB) use of its statutory authority under the Dodd-Frank Act to exempt any class of providers [community banks] or any products or services from the rules it writes, focus of regulation of financial products on the mega banks and financial firms and the unregulated shadow financial industry, community bank flexibility to meet the unique needs of its customers, burdening community banks with additional and unnecessary regulatory requirements that could prevent them from serving their communities, a one-size-fits-all approach to CFPB regulations, influencing the marketplace behavior by targeting of financial institutions, products, services, practices deemed to be undesirable or inappropriate, replacing single-Director governance with a five-member commission, prudential regulators participation with the CFPB in the rule-writing process, and the Financial Stability Oversight Council (FSOC) power to veto CFPB rules. Maintain the Federal Home Loan Bank System - The regional structure, special functions and purposes of the FHLBs, the System remaining a financially sound, stable and reliable source of funding for its members, reliance upon it as the sole aggregator or securitizer of residential mortgages for community banks, the FHFA imposing an ongoing housing mission asset test on community financial institutions, rulemaking to restrict FHLB membership eligibility requirements. (House, Senate) Legislation - H.R. 10 - Financial CHOICE Act (financial regulations) (All Sections but particularly Title V, debit interchange, repeal of 10% cap on deposits/liabilities) (House) H.R. 2890 - Housing Opportunity Mortgage Expansion Act (captive insurance company membership in the FHLBs) (All Sections) (House) H.R. 2133 - Commercial Lending Enhancement and Regulatory Relief Act of 2017 (CLEARR Act of 2017) - (regulatory relief) (All Sections) (House) S. 1002 - Commercial Lending Enhancement and Regulatory Relief Act of 2017 (CLEAR Relief Act of 2017) (regulatory relief) (All Sections) (Senate) Comment Letters - Comment Letter - OCC - Summary of Comments and Explanatory Statement: Special Purpose National Banking Charters for Financial Technology Companies, and Licensing Manual Statement for Evaluating Charter Applications From Financial Technology Companies Comment Letter - NCUA - Advanced Notice of Proposed Rulemaking for Supplemental Capital; Docket ID: NCUA-2017-0007; FR #2017-01713 Comment Letter - CFPB - Proposed Rule with Request for Comments - Home Mortgage Disclosure (Regulation C); CFPB-2017-0010 or RIN 3170-AA64 Action Alerts - Action Alert - Regarding NCUA alternative capital rules - Oppose credit union alternative capital rules Action Alert - Regarding CLEAR Act - Urge Illinois congressional delegation to cosponsor the CLEAR Act. (H.R. 2133) Miscellaneous - OCC issuing special purpose national banking charters for financial Technology (fintech) companies (House and Senate) CFPB small business data collection (upcoming proposal) (House) | Consumer Financial Protection Bureau (CFPB),HOUSE OF REPRESENTATIVES,Natl Credit Union Administration (NCUA),Office of the Comptroller of the Currency (OCC),SENATE | 55000 | 0 | 0 | 2017-07-14T14:20:20.443000-04:00 |