{"database": "lobbying", "table": "lobbying_activities", "rows": [[2300023, "48f68c1b-0ce8-4b04-a1a4-fa2b217e0c16", "Q2", "COMMUNITY BANKERS ASSOCIATION OF ILLINOIS", 400531588, "COMMUNITY BANKERS ASSOCIATION OF ILLINOIS", 2019, "second_quarter", "AGR", "Federal Policy Priorities - 2019 \n\nThe Community Bankers Association of Illinois (CBAI) supports fair competition for financial services, tiered regulation, the separation of banking and commerce, the dual banking system/charter choice, and financial innovation; and opposes discrimination favoring certain financial service providers, banking industry consolidation and systemic risk. \n\nThe Independent Community Bankers of Americas legislative and regulatory agenda contained in their Community Focus 2020: The Community Bank Agenda for Expanding Economic Opportunity proposes a more efficient system of regulation, unbiased laws governing the financial sector, a safer and more secure business environment, and more efficient agricultural policies to extend the nations economic growth to every corner of the country.\n\nThe swift implementation of the remaining regulatory relief provisions for community banks - consistent with Congressional intent - contained the Economic Growth, Regulatory Relief and Consumer Protection Act (S. 2155) which became law in May of 2018.\n\nThe passage of additional meaningful regulatory relief for community banks including modernizing the Bank Secrecy Act (BSA)/Currency Transaction Report (CTR) threshold/Suspicious Activity Report (SAR) threshold. Also, data for the new beneficial ownership reporting requirements should be collected and verified by the appropriate federal/state government agencies when a legal entity is formed or when subsequent changes occur. \n\nCredit unions and Farm Credit System (FCS) lenders have long-since strayed from their founding purposes, blatantly abusing their competitive advantages. This blatant and continuing discrimination against community banks must end. Either the credit union and FCS competitive advantages must be reined-in or there must be tax credits or deductions for community banks lending to small businesses, farmers and ranchers, homebuyers, and low- and middle-income individuals. These changes in the tax code would help sustain and strengthen community bank lending and would begin to offset the competitive advantage enjoyed by tax-exempt credit unions and FCS lenders.\n\nThe United States payments system (System), which is the very foundation of our financial services and economy, must be modernized to meet the demands of consumers and to keep pace with the rest of the world. System improvements must not be dominated by the largest banks and financial firms or private-sector non-banks. Community banks, small businesses and consumers must rely on the Federal Reserve to provide access to a safe and secure payments system which requires the Federal Reserve to continue to play a preeminent role in the Systems improvement.\n\nThe Community Reinvestment Act (CRA) needs to be updated to incorporate new financial products and services delivered in modern ways. Community banks have traditionally excelled in the performance of their CRA compliance and examinations. The modernization of the CRA must enhance the ability of community banks to serve their communities and must not impose any additional regulatory burden. All financial service providers must be subject to the CRA to provide a complete picture of financial institutions performance in serving their communities - including credit unions, Farm Credit System lenders and Fintechs (including the OCCs Special Purpose National Banks).\n\nThe reform of the housing GSEs remains critically important to the future of the housing market and the U.S. economy. American homeowners have benefited from the critical role Fannie Mae and Freddie Mac have played in helping finance homeownership for many decades. The GSEs have provided a steady, reliable source of funding for home mortgage lending through all economic cycles and in all markets. Community banks depend on the GSEs for direct access to the secondary market without having to sell their loans through larger financial institutions that compete with them. The GSEs allow community banks to retain the servicing of the loans they sell, which helps to keep delinquencies and foreclosures low. And, unlike other private investors or aggregators, the GSEs have a mandate to serve all markets at all times which is critical to maintaining liquidity when the markets are experiencing financial stress.\n\nMost community banks are members and shareholders of their regional Federal Home Loan Bank (FHLB). The FHLBs provide short-term liquidity, long-term funding, mortgage-related products, and other financial services in order to help their members provide affordable credit to the local communities they serve. The regional structure, special functions and unique purpose of the FHLBs must be recognized and maintained by the Federal Housing Finance Agency (FHFA). As the Administration and Congress consider reforming the housing finance system, care must be taken not to harm the FHLBs. They must remain healthy, stable and reliable sources of funding for their members . However, given their unique relationship with thousands of community lenders, it may be appropriate for the FHLBs to support their members secondary market activities as aggregators or guarantors for residential mortgage loans, provided their current ability to serve their members is not impeded or threatened. Additionally, the FHFA should not impose an ongoing housing mission asset test on FHLB membership, which would undermine the reliability of FHLB funding. \n\nA vibrant agricultural and rural economy is vital to Americas prosperity.  The multi-year Farm Bill provided a strong safety net for farmers and ranchers including adequate price-protection programs and enhanced USDA-guaranteed farm and business loan programs. These programs must be protected from further cuts or adverse changes that would discourage farmer and rancher participation or undermine private-sector delivery. \n\nCommunity banks are strong guardians of the security and confidentiality of their customers information and are on the frontline of defending against cyber security threats. Core data security principals in legislation and regulations must include the complete cost of data breaches being borne by that party that caused the breach; all participants in the payment system 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, only to achieve the same superior results they currently attain.\n\nWhile community banks represent less than 20% of banking industry assets, they make 60% of the small business loans and 80% of agricultural loans. The requirement for reporting small business data collection stems from Section 1071 of the Dodd-Frank Act and is meant to facilitate the enforcement of fair lending laws in small business lending. The data, however, clearly suggests fair lending is not a problem at community banks as they treat their customers honestly and fairly. The regulatory burden of the collection and reporting requirements fall disproportionately hard on community banks that lack scale and compliance resources, and Section 1071 should either be repealed or community banks should be provided with a meaningful exception.\n\nThe recent financial crisis, taxpayer bail-outs and subsequent recession was caused by the misconduct of the nations largest banks and financial firms (Too-Big-To-Fail Banks and Financial Firms). The Dodd-Frank Act was intended to reign-in their destructive behavior. Unfortunately, this was an inadequate legislative and regulatory response which has allowed these financial behemoths to grow in size, complexity and influence; they will continue to abuse their consumers; and they remain a significant threat to our financial system and economy. These megabanks have proven, at great cost to American taxpayers, that they cannot be effectively managed, supervised or disciplined. They are clearly too-big-to-change, too-big-to-fail and must be downsized.\n(House, Senate, FDIC)\n\n\nAction Alerts -\n\nAction Alert regarding raising coverage thresholds for collecting and reporting data about closed-end mortgages under the Home Mortgage Disclosure Act (HMDA) to 100 loans and making permanent the 500 open-end lines of credit threshold instead of reverting back to 200 in 2022 (CFPB)\n\nAction Alert regarding tax-exempt credit unions purchasing taxpaying community banks (House and Senate)", "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, 60000, 0, 0, "2019-07-08T16:31:27.687000-04:00"]], "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": ["2300023"], "units": {}, "query_ms": 297.69453196786344, "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"}