{"database": "lobbying", "table": "lobbying_activities", "rows": [[2029345, "c389dcae-215a-4a26-a66f-5616191878bc", "Q3", "COMMUNITY BANKERS ASSOCIATION OF ILLINOIS", 400531588, "COMMUNITY BANKERS ASSOCIATION OF ILLINOIS", 2017, "third_quarter", "BAN", "Regulatory relief for community banks in the 115th Congress\n\nTiered regulation and supervision for community banks as contained in the Independent Community Bankers of Americas (ICBA) Plan for Prosperity\n\nThe ICBAs Plan for Prosperity contains the following issue areas and recommendations.\nAccess to Capital\n\nRestore the original intent of the Basel III rule\nCreate a more accurate identification of systemic risk\nSpur additional capital for small bank holding companies by modernizing the Federal Reserves policy statement\nRelieve community banks from excessive Securities and Exchange Commission rules\nRepeal the Collins Amendment for non-SIFIs\nAddress minority bank capital challenges\n\nRegulatory Relief\n\nBalance consumer regulation through more accountable Consumer Financial Protection Bureau governance\nEliminate arbitrary disparate impact fair lending lawsuits\nEnsure the viability of mutual banks through new charter and capital options\nSupport rigorous cost-benefit analyses of all new rules to determine if they are justified and indeed needed\nModernize the Bank Secrecy Act (BSA)\nCut the red tape in small business lending by eliminating burdensome data collection\nTarget the Volker Rule on a banks individual risk\nPreserve access to investment advice for middle-class savers\n\nMortgage Reform\n\nCreate a safe harbor from onerous underwriting standards\nEstablish relief from burdensome HMDA, escrow and appraisal requirements\nPreserve the ability for community banks to continue servicing mortgage loans\nReform the closing process and accompanying paperwork\n\nBank Oversight and Examination\n\nStrengthen accountability in bank exams and create a workable appeals process\nReform bank oversight and examination to better target risk\n\nTax Relief\n\nLower marginal rates needed for individuals, corporations and businesses\nIncentivize credit for low- and middle-income customers and American agriculture \nModernize Subchapter S constraints\nCreate limited liability corporation (LLC) option for community banks\nRepeal the estate tax\nUpdate the bank qualified (BQ) bond issuer limitation\nSupport a five-year loss carryback that encourages lending during economic downturns\nCreate a tax credit for Bank Secrecy Act (BSA) compliance costs\n\nAgriculture and Rural America\n\nAddress arbitrary agricultural loan concentration limits\nInstitute tax relief for rural lending \n\n(House, OCC, FDIC, CFPB)\n\n\nCBAI 2017 Federal Policy Priorities\n\nMeaningful 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.\n\nRegarding the implementation of regulatory initiatives -\n\nSpecial purpose fintech national bank charters by the OCC to financial technology companies  \n\nFinancial Accounting Standards Board (FASB) Current Expected Credit Loss Model (CECL)\n\nConsumer Financial Protection Bureaus (CFPB) proposed payday and vehicle title (small-dollar credit) lending rules\n\nDe novo bank formation, the dual banking system, and charter choice \n\nThe issue of too-big-to-fail banks and financial firms - protect our financial system, economy and taxpayers from future bailouts -\n\nCredible 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.  \n \nNew Farm Bill and abolishing (or reigning-in) the Farm Credit System, crop insurance, USDA loan guarantee programs - volume caps and additional funding -\n \nExpansionist 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.  \n \nTaxation of credit unions and their expansion of powers -\n \nOutdated 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. \n \nEnhanced data, cyber and payment card security (data security) -\n \nWide-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.\n\nCommunity 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.  \n\nData 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.  \n\nCommunity 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. \n  \nMortgage lending and housing finance reform -\n \nCommunity 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 \n \nCommunity 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. \n \nRegarding 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. \n  \nConsumer Financial Protection Bureau Reform -\n \nThe 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.\n \nMaintain the Federal Home Loan Bank System -\n \nThe 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.\n\n(House, OCC, FDIC, CFPB)\n\n\nLegislation -\n\nH.R. 2890 - Housing Opportunity Mortgage Expansion Act (captive insurance company membership in the FHLBs) (All Sections) (House and Senate - companion legislation)\n\nH.R. 2133 - Commercial Lending Enhancement and Regulatory Relief Act of 2017 (CLEARR Act of 2017) - (regulatory relief) (All Sections) (House)\n\nS. 1002 - Commercial Lending Enhancement and Regulatory Relief Act of 2017 (CLEAR Relief Act of 2017) (regulatory relief) (All Sections) (Senate)\n\nS.1500 - - Keeping Capital Local for Underserved Communities Act of 2017 (reciprocal deposits as brokered deposits) (All sections) (Senate)\n\nH.R. 2403 - Keeping Capital Local for Underserved Communities Act of 2017 (reciprocal deposits as brokered deposits) (All sections) (House)\n\nH.R. 2954 - Home Mortgage Disclosure Adjustment Act (HMDA thresholds) (All Sections) (House)\n \n\nComment Letters -\n\nComment Letter -   CFPB - Proposed Rule with Request for Public Comment - Home Mortgage Disclosure (Regulation C): Temporary Increase in Institutional and Transaction Coverage Thresholds for Open-End Lines of Credit: CFPB-2017-0021 and RIN 3170-AA76\n\nComment Letter - OCC, FDIC and Federal Reserve - Proposed Agency Information Collection Activities; Comment Request, FFIEC 031, FFIEC 041, and FFIEC 051\n\nComment Letter - CFPB - Request for Information Regarding Small Business Lending Market; Docket No. CFPB-2017-0011\n\nComment Letter - OCC - Notice Seeking Public Input on Volcker Rule - Docket ID OCC- 2017-0014\n\n\nMiscellaneous -\n\nS. J. Res. 47 - Arbitration Rule - Trade Industry Letter (Senate)\n\nPrincipals of Tax Relief and Reform (House, Senate, OCC, CFPB, FDIC)\n\nSupport for Agricultural and Rural America (House, Senate, OCC, CFPB, FDIC)\n\nPrincipals of new multi-year Farm Bill (House letter)\n\nPrincipals of GSE Reform (House roundtable)\n\nExpansionist Agenda of Credit Unions and the Farm Credit System (House, Senate, OCC, CFPB, FDIC)\n\nDisparate Impact causes of action (House)", "Consumer Financial Protection Bureau (CFPB),Federal Deposit Insurance Corporation (FDIC),Federal Reserve System,HOUSE OF REPRESENTATIVES,Office of the Comptroller of the Currency (OCC),SENATE", null, 55000, 0, 0, "2017-10-18T11:30:07.793000-04:00"]], "columns": ["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"], "primary_keys": ["id"], "primary_key_values": ["2029345"], "units": {}, "query_ms": 0.4940230865031481, "source": "Federal Register API & Regulations.gov API", "source_url": "https://www.federalregister.gov/developers/api/v1", "license": "Public Domain (U.S. Government data)", "license_url": "https://www.regulations.gov/faq"}