The following was submitted in the form of a comment:
I’d like to have some opinions about the bill that I’m writing to replace citizenship with residence-based taxation. Maybe someone could move this to a different page if it gets too long. By the way, I’m about one third of the way through with the relevant sections in the Internal Revenue Code.
1. To define residence, I am using the current substantial presence test with all of its rules and exceptions. This is the definition that is currently used for foreigners without a green card, so I am just applying it to everyone. I am also adding an exception to consider US government or military employees abroad as residents, because their salaries are sourced in the US and they would pay higher taxes if they were considered nonresidents. I am also adding that US citizens and permanent residents who don’t satisfy the substantial presence test may elect to be treated as residents for tax purposes by simply filing the normal resident tax forms (1040). I understand that there are some cases where this may be beneficial, and I don’t want to increase taxes on anyone.
2. Because some people may elect to be treated as US residents even if not acually residing in the US, I am keeping the foreign earned income exclusion and the exclusion of income from US possessions available. It may be hard for you to imagine, but there are situations where using the exclusions is better than being a nonresident. For example, this occurs for those residing in a low-tax country or US possession who have income from US sources and a low total income.
3. To be consistent with the concept that citizenship should not be used for taxation, I am removing the requirements that certain dependents be “citizens or residents”. If I changed the requirements to only “residents”, some people might not be able to claim dependents that they currently claim, and again I don’t want to increase taxes on anyone.
4. Also to be consistent with eliminating the use of citizenship, I am repealing the sections that allow higher taxes on those whose country of citizenship or residence impose higher taxes on Americans. (I don’t think this provision has ever been used anyway.)
5. Again to be consistent, I am removing the requirement that the spouse be a US citizen for the estate tax exemption. I am also allowing the exemption from US estate taxes to all residents of US possessions, not just who were born there.
6. I was trying to restructure the exit tax based on termination of residence, but I decided to repeal it completely. My understanding is that the main reason for the exit tax in the US is not to collect revenue on unrealized gains, but to penalize rich people who renounce US citizenship to avoid taxes, because certain dual citizens, permanent residents with less than 8 years of residence, any residents only by virtue of the substantial presence test, and any people not considered “rich” are exempt from it, while those who do not certify current tax compliance are not exempt even if not “rich”. The whole idea of renouncing citizenship because of taxes does not exist in a residence-based system. One could argue that taxes would then be a motivation for terminating residence, but I’m not aware of any US state that imposes an exit tax. Some countries have foreign exchange control but not an exit tax per se. As far as I know, only Canada has a real exit tax, and the Netherlands can only impose it under a treaty with the new country of residence. I also don’t agree with taxing unrealized gains because they are not final and could decrease, just like what happened to Eduardo Saverin’s Facebook shares. Besides, the gains may be taxed by the new country of residence once realized; if it doesn’t tax capital gains, it probably collects more revenue from other taxes or other sources instead, or it spends less. Likewise, I decided to repeal the estate tax on inheritance from “covered expatriates”.
7. I am getting tempted to include in the bill a complete repeal of FBAR, FATCA and even the whole estate tax. It’s very easy to write “section #### is repealed”. But those are separate issues and I guess I shouldn’t try to fix everything, I don’t even know if my bill will be introduced at all. I think it’s better leave the unconstitutionality of the FBAR penalties for the courts to decide, a repeal of FATCA for the banks to lobby, and a repeal of the estate tax for the Republicans in Congress. Citizenship-based taxation is the issue that no one else cares about.
I met with Marylouise Serrato today. She was nice, but overall I was disappointed with the meeting. In sum, she said that ACA has been trying to propose residential taxation for over 30 years and that eventually they understood that Congress simply doesn’t care about Americans abroad. She said that ACA basically gave up trying to convince Congress based on arguments of fairness, and that the only way that Congress would approve residential taxation is if it would somehow result in higher tax revenue, or have a positive effect on US exports or jobs. So now ACA is trying to make a proposal that would reflect this idea.
I argued that no matter what proposal ACA makes, it is mathematically impossible to have a higher tax revenue with fewer people paying taxes (and if taxes on other people don’t increase), but that in any case the effect would be insignificant based on data from the IRS itself. She agreed, but she said that Congress is still obsessed with any loss of revenue and the perception that they might be giving a tax break to millionaires to flee the country and avoid taxes.
I still want to help ACA, but I’m feeling that they won’t get anywhere with their current mentality. The personal issues that you all describe in this blog (stress, despair, feeling of injustice, “loss of LCUs”) are what motivates me, and for me this aspect is much greater than numbers on a government report. I cannot believe that congressmen would be so cold and not show any sympathy for the lives of their own people, because of such a relatively small amount of money that ends up getting lost in margins of error of subjective estimates. This is not a discussion about revenue, tax rates, exemptions and loopholes, it’s not even about money really, it’s about logic, fairness and letting people live freely.
So now I want to go talk to congressmen on my own and see if I can get anywhere with my bill, or if what ACA described is really true. The only problem is that I need some kind of support. They won’t believe some crazy guy who goes there talking about things they have never heard of like FBAR penalties and Eritrea. Can I have your support? Would it be correct to say that I’m representing a group of Americans abroad and immigrants to the US? Petros, just to have an idea, how many people read or participate in this blog?
@ShadowRaider;
I am sad to hear that the meeting was disappointing, it sounded hopeful. We appreciate your efforts. And, some problems need a multi-prong approach – sometimes it is in combination with other efforts that change happens.
It is daunting that asking for fairness and just treatment isn’t sufficient, and that to pursue those few storied fleeing millionaires, Congress is satisfied with continuing to persecute 6 million living outside the US – with no limit, not much return, and no good reason. Those actually actively ‘evading’ US taxes are most likely actually living there, inside the US – like the Fortune 500 companies registered in Delaware.
In terms of pursuing this with individual US politicians, the difficulty with being able to say that you ‘represent’ (even loosely) a group of Americans abroad is that we are a very informally affiliated set of diverse individuals here – we have no set structure, and have a range of relationships to this problem. Designating someone as a ‘representative’ is a big challenge I think, though others here might have a different thought about it. We did not get very far with earlier attempts here with something similar like a group letter.
I hope you don’t think that means those here don’t appreciate the huge efforts you’re making on behalf of those living abroad – which is very altruistic of you – you have nothing to gain.
*Shadow Raider, you have my support. Just let me know what you want for me to do.
*Shadow Raider
I would not necessarily discount ACA’s approach as being unworkable. I will try to post some more things later today. All I will say is don’t necessarily assume that the current system generates more revenue for the US government than a would be residential based tax system.
@badger, You don’t have to set a structure. I just want to be able to say that I’m bringing the real concerns from a group of people, to legitimize my request for a meeting.
@swisspinoy, Thank you. Right now, you don’t have to do anything. But I’ll ask you for more information later if I need it.
@Tim, I know that there are secondary effects such as increased exports, lower unemployment as more Americans may search for jobs abroad, new immigration or retention of wealthy immigrants in the US, and perhaps a general sense of support for the US among its diaspora. But I don’t know to quantize these things. Apparently, ACA is trying to show a numerical estimate. Specifically, they are proposing that Americans residing abroad have the option to be treated as nonresident aliens for tax purposes, by filing a form, paying the exit tax if required, and paying a one-time $1000 processing fee. ACA wants to claim that this would compensate the future loss of revenue, but I don’t think it will. Besides, such proposal would add even more complexity to the US tax code.
@ShadowRaider, the IRS doesn’t even have good statistics. Neither does the GAO. In their reports of the storied ‘tax gap’ and the amount they attribute specifically to those ‘abroad’, they admit they have no good or reliable numbers – just look at their footnotes and see what they cite in support of their quantifying. And they know that for the most part, the FEIE plus tax credits work to eliminate some types of assessed US tax for a substantial number of people. Now I wouldn’t put it past them to have some type of actuarial scheme predicting how much might be out there from the bulge of the baby boomers aging and leaving estate assets abroad, and also using returns (and the info on the 3520/A) from abroad to datamine for information about relatives to persecute inside the US. Its not just actual ‘taxpayers’ they’re after, but sources of information to datamine. But perhaps IRS projections could be countered by a really good statistician or epidemiologist. And it is also possible that if the IRS and Congress are counting on keeping the elimination of the FEIE in reserve as a possibility, then they don’t care about the current numbers who wouldn’t actually owe US tax – because it is really more part of a planned future initiative to make more people abroad liable to pay tax – through penalties and through changing how we are assessed. And, why let real numbers get in the way of political rhetoric – if it serves US politicians?
I don’t trust them at all. I see also that there is a new draft of the 8854, dated September 2012, which distinguished between obligations for those renouncing before 2012, in 2012 and vs. afterwards. Google : “September 19, 2012. DRAFT AS OF. 2012. Instructions for Form 8854. Initial and Annual Expatriation Statement. Department of the Treasury. Internal Revenue” I firmly believe that this is all different aspects of an overall plan to stop us from renouncing, and to squeeze as many of us as possible. They can’t outright ban renunciation, but they can do it by de facto – which is almost what is already the case by making it contingent on jumping through establishing and swearing to 5 years worth of IRS ‘compliance’ or risk perjury, etc.. Maybe our best bet is to embarass the US from abroad as much as possible, or go to the UN to charge that they are de facto violating international human rights to choose and shed citizenship. It doesn’t have to be binding on the US, or to succeed in order to help us – since the bad international PR is also a powerful force – shedding light on US arrogance and extraterritorial taxation worldwide – which would work against the success of FATCA – and also embarass and taint the other governments who sign onto it.
@Shadowraider
I’m sorry that you feel discouraged. Thank you for your efforts, and count on me to help any way I can. I don’t feel encouraged either that those within the US will find any kind of motivation to change course. Only the lessons learned from serious self-inflicted wounds (like unfunded wars) will make a difference to these myopic visionaries. We must continue pressuring our own governments in the countries where we live to try to persuade the US government that their course of action isn’t mutually beneficial.
@badger, Compare with current form 8854, they merely updated it by replacing “2011” with “2012”. The obligations didn’t change in 2012, it’s just that the same form is used for two purposes: those who expatriate in the current tax year, and those who expatriated in previous years and deferred the exit tax.
Thank you Shadow Raider. By default now, I just don’t trust anything that the US, the IRS, the Treasury, the DOJ, etc. do that has any bearing on us who live outside the US. I believe that they will seek to make it even harder for those who seek to renounce/relinquish. They do not have fairness, ethics or justice as their guiding principles.
*I’ve been “unsubscribing” from democrats.org about 2 or three times per day now. Unsubscribing for .com email addresses seemed to work, but the spam keeps on coming for the .ch email address. The first 3 or so times of unsubscribing, I stated that I was doing so due to the lack of responses to my inquiries. Now, I simply write that I already unsubscribed each time that the spam arrives again.
So, badger, add democrats.org to your “do not trust list” too. It’s nothing but spam. At least republicans honored the “unsubscribe” feature (i think).
@Shadow Raider,
I’m late to the game. All I can say is thank you for your outstanding efforts and echo what everyone else has said to you today. I will support you.
@Shadow Raider and everyone else, don’t give up. There are many ways to get people to work on the problems Americans citizens abroad have. I support ACA as much as I can right now, but here are some other things that I have done that have elicited responses that continue to give me hope, although I do not see any change in the short term. Maybe they would be additional ways that you can contribute on top of what you are already doing.
1. If you are still American, figure out who your Congressperson is and contact them, persistently. E-mail is better than by letter. It helps if you have a specific problem that you can refer to and/or indicate support for a specific bill such as HR 6263 (for studying problems of Americans abroad – yes this is moving at a glacial pace, but it is an attempt to draw attention to the issues). So anyone in OVDI basically has a specific issue that they can use to mobilize their Congressperson.
2. If you get your Congressperson’s attention, then have him or her contact Carolyn Maloney’s Chief of Staff, Ben Chevat. My Congresswoman was skeptical about OVDI’s excessive punishment of Americans acting in good faith, but changed completely after contacting other Congresspeople’s staff. She has been helpful in contacting the IRS to address my concerns. While I believe the IRS has brushed her off twice, she is now aware of the difficulties her overseas constituents face. That can only help us.
3. Submit Systemic Advocacy complaints to the TAS. Describe specific problems and show how they relate to a group of taxpayers. In my case, I described how an IRS agent was impossible to contact and our correspondence by letter was taking 40 days, thus dragging out my case. I cited how ridiculous it was for the IRS to pursue international tax enforcement with the policies and tools made for US residents. It only led to me feeling like I got poor service as a customer and probably did not help the relationship with the examiner. Within a few weeks, I received a call back from SAMS, the TAS service that monitors complaints on behalf of groups of taxpayers and we talked for 1.5 hours. What a catharsis! I laid out my experiences and also concerns about PFICs and more. I was offered help by having my case being taken up by the TAS. I did not need to take it as my case had already been accepted by the TAS, but she did not know this. The SAMS woman mentioned they had already taken statements from many Canadians about the situation with respect to the retirement plans in Canada, so if you have not submitted a statement yet, it would add more weight if you would do so. Just don’t forget those of us not in Canada who also have “foreign” retirement plans. 😉
4) If you have constructive criticism related to a specific problem, write Nina Olson, the Head of the TAS. I did and she wrote me back and some of the issues are being addressed. She had been addressing them already, but my experiences, all documented, add fuel to the fire. You can also try posting on her blog, which she moderates. I am sure these concerns will be taken to Congress and can in some way influence policy within the IRS.
There are other things I plan to do, like signing a waiver so that my statements and case can be presented to Congress, dedicating a vacation to visiting the Members of the House and Ways and Means Committee and more.
I have also written my local politicians in my country of residence and talked to reporters worldwide. My politicians in my country of residence are not interested due to the small amount of Americans here. However, this helps raise awareness. I have forced myself to go out and join expat clubs where I live. That was hard for me because I did not consider myself an expat. I am a dual (actually triple) national, who was fully integrated into the society I was living in. I did not have a need, nor was I required to associate with Americans. Now I do so to educate them, but sadly most are in a state of denial and say it cannot happen to me.
The smart thing to do would be to renounce as I have no ties to America other than emotional ones, but as I am stuck in the system due to OVDI, I am going to use this time productively to do what I can for myself and others.
@Lisa, at great personal cost, you’ve done so much. The actions will help many people, and the suggestions you’ve made will help all of us pursue additional avenues. Others here did submit to SAMS, and more than one has spoken with a TAS representative, on various issues, some re OVDI, some on other facets of this.
You’re very right to remind us who know only the Canadian situation best, that others also have registered pension plans and retirement savings that are at threat because the US does not recognize them at all (unlike the RRSP – with a partial recognition – via annual election – and now perhaps a retroactive method?). The US has not made any effort to stop penalizing people living outside the US for having entirely legal savings for retirement and/or disability – no matter what country they live in. And I know that authors here have told us that in countries with different tax systems, the US does not even give credit if their home country taxes are not recognized as a tax on ‘income’ per se. We tend to focus on what we know best here, but others have even more burdensome treatment depending on the country.
Bless Nina Olson and the Taxpayers Advocate Service – otherwise we’d have no IRS recourse at all. It is entirely unjust that more has not been done to help those who only by virtue of coming forward in the OVDI, which the IRS encouraged, and many practitioners advised, are facing the entire loss of their savings, and incurring huge debt through high professional fees, and are stuck in a system that prejudges and pre-sentences all as criminals. Many many others are waiting on the sidelines still trying to decide what to do, or still completely unaware.
I forgot to say that the SAMS woman was also interested in Form 3520 and 3520A issues. She said in previous years there had only been a small number of these filed and now there are hundreds of thousands of them being filed and hundreds of thousands of people in fear of penalties. Some are receiving penalties and calling in. We discussed how it was impossible to know if an account you have is a trust or not. Where is there a list? How would the average person living overseas in a country with few US accountants available know this? If we are supposed to rely on IRS.gov, why isn’t there a list there? Why does 3520A have a different filing date than 3520? What makes something a trust? Why can’t the IRS describe it easily? Why does this information requirement need to exist at all for Americans abroad?
*@Lisa, I also worry about the possible ‘foreign trust’ issues involving my ISA (even though it’s in a USA-compliant portfoliio) as well as my pension plan set up by my employer. It would at least double if not triple my annual accounting fees if I had to file those 3520 and 3520A foreign trust forms!! And I’m already looking at approx $2500-3000 per year with my current accountant even before considering the potential extra costs these forms would add on to this already burdensome ‘rent’ charges for my ‘glorious’ US citizenship.
As I’ve already mentioned in earlier posts, I am grudgingly prepared to budget for up to $5000 per year to stay compliant, but if it starts going above that, then I’m simply not going to be able to afford to maintain my US citizenship…though it could mean being banished from even being allowed to visit my parents who are in their 70s. They understand that I may need to renounce but it will break their hearts if I can’t continue to visit because of the possible ex-patriot act or something similar.
@Mona Lisa – I can only encourage you to add your voice by submitting an issue to SAMS. I was not worried about 3520s, the SAMS lady brought it up and asked me if it affected me. I think your data on your accounting costs would be valuable input for the reports that the TAS makes. I know you are very scared, but your confidentiality will be respected.
@Lisa
These are great suggestions. It’s unfortunate that that those in government in your country of residence aren’t taking more of an interest. Won’t your financial institutions be effected by FATCA?
I too am grateful for the work Nina Olson does, and and my husband and I were encouraged by the one lengthy discussion we had with a TAS agent, and through their assistance we could avoid penalties through the IRM while in OVDI. Let’s keep in mind, however, that Ms Olson’s function is merely a facet within what we ultimately need to abolish, which is citizenship based taxation. It’s not her place to advocate for its elimination, but merely to improve the conditions for those enslaved by it.
@Lisa and @Mona Lisa. Thanks for your comment to Mona Lisa, Lisa. I absolutely concur and also encourage you, Mona Lisa, please submit your issue to SAMS.
Here is the link if you don’t have it: http://www.irs.gov/uac/Systemic-Advocacy-Management-System-(SAMS).
Your being part of reporting to SAMS would be a valuable contribution to how it is affects US Persons Abroad and may eventually help you as well as many others.
@bubblebustin – My foreign minister told me that my country will seek the same solution across the EU. So the deal that the Big 5 will get will be asked for. My country wants to be a good EU member.
As for the banks, they are moving ahead with FATCA implementations. They have protested at public hearings, but in actual fact, they are trying to comply. The wives of two colleagues of mine work in the IT department of major banks and insurance companies and both have been put into high priority FATCA projects. My colleagues tell me that thanks to what I have been telling them, they can actually have intelligent discussions with their wives about FATCA.
As for the TAS and helpful suggestions, I am aware they have told you about the FTA for a first time FTF or FTP or FTD penalty. Their lawyers also pointed out to me that within OVDI, the accuracy penalty is an add-on. Outside of OVDI, if you have never been filing, how can an accuracy penalty be assessed if you have never been inaccurate? So this is another reason for considering opting out and not allowing yourself to be bullied into paying this penalty or even suggesting that you pay it in your opt out letter.
@bubblebustin – I noticed that you are saying and have said that the TAS agent told that you may be able to avoid penalties through the IRM while in OVDI. Do not count on this. If you are accepted by TAS, a Revenue Agent Tax Analysts (RATA), i.e., a technical advisor, will likely be called in to help your Case Advocate assess your facts. In my case, one of the TAS attorney advisors on OVDI has also become involved. The message from all is clearly that OVDI allows no scope for any application of penalty relief based on the IRM. So one has to make the decision to opt out or not. So prepare yourself for this in terms of the emotional and lawyer’s costs. My case is being worked on now, so if I see any leniency in the policy, I will let you know. I sure hope it will be that way, but the TAS experts I am working with don’t see it happening. Maybe we will all be pleasantly surprised, but I am not holding my breath.
Thank you all for your support. I guess I overreacted, because I just received an email from Marylouise saying that, since ACA will probably not release their updated tax proposal soon, I can surely contact representatives on my own and refer them to the current general proposal from ACA, which is what I tried to implement in my bill draft. So, next week I’m planning to call the offices of congressmen to schedule meetings. I’m considering the following congressmen, as they have shown interest in the subject before:
Senator Rand Paul (R-KY) (opposes FATCA)
Senator Jim DeMint (R-SC) (opposes FATCA, proposed extension of FEIE)
Senator Mike Lee (R-UT) (opposes FATCA)
Senator Saxby Chambliss (R-GA) (opposes FATCA)
Representative Ron Paul (R-TX) (opposes Ex-Patriot Act, cosponsored extension of FEIE)
Representative Scott Garrett (R-NJ) (proposed extension of FEIE)
Representative Gregory Meeks (D-NY) (proposed extension of FEIE)
Representative Carolyn Maloney (D-NY) (proposed commission for Americans abroad)
Representative John Campbell (R-CA) (cosponsored extension of FEIE)
Representative Jeff Flake (R-AZ) (cosponsored extension of FEIE)
Representative Phil Gingrey (R-GA) (cosponsored extension of FEIE)
Representative Wally Herger (R-CA) (cosponsored extension of FEIE)
Representative Mike Pence (R-IN) (cosponsored extension of FEIE)
Representative Joe Pitts (R-PA) (cosponsored extension of FEIE)
Representative Paul Ryan (R-WI) (cosponsored extension of FEIE)
Representative Sam Johnson (R-TX) (cosponsored extension of FEIE)
Representative John Culberson (R-TX) (cosponsored extension of FEIE)
Representative Jeff Miller (R-FL) (cosponsored extension of FEIE)
Representative Marsha Blackburn (R-TN) (cosponsored extension of FEIE)
Representative Darrell Issa (R-CA) (cosponsored extension of FEIE)
Representative Steve King (R-IA) (cosponsored extension of FEIE)
Representative John Kline (R-MN) (cosponsored extension of FEIE)
Representative Tom Price (R-GA) (cosponsored extension of FEIE)
Representative John Sullivan (R-OK) (cosponsored extension of FEIE)
Representative Lynn Westmoreland (R-GA) (cosponsored extension of FEIE)
Representative Mike Honda (D-CA) (cosponsored commission for Americans abroad)
Representative Charles Rangel (D-NY) (cosponsored commission for Americans abroad)
Representative Rush Holt (D-NJ) (cosponsored commission for Americans abroad)
Any other suggestions?
By the way, I checked the US constitution to see if a senator could propose my bill. According to section 7 of article 1, “All bills for raising revenue shall originate in the House of Representatives; but the Senate may propose or concur with amendments as on other bills.” My bill doesn’t raise revenue, but I guess it would fall under this rule because it is tax reform. However, even if senators cannot propose my bill directly, they could propose it as an amendment to a future tax bill originating in the House of Representatives, according to the constitution. In fact, this is what happened to FATCA.
*I have been reading posts here and would like to thank everyone. I am following Lisa’s suggestion and looked up Bill HR6263 and am going to write my position on the bill. It will be sent to my congressperson as well. This goes directly to congress and I think everyone should voice their opinion on it. https://www.popvox.com/bills/us/112/hr6263
Bravo Shadow Raider!
@Expat4ever, Thanks.
An interesting case, which I have mentioned in this blog before, is that of French citizens living in Monaco. Other than Americans and Eritreans abroad, they are the only people permanently subject to citizenship-based taxation in the world. In the beginning of this year, the matter was discussed at the French Senate. A few months ago, France held elections for representatives of French citizens abroad for the first time. Even though only 7% of French voters in the relevant district live in Monaco (the district also includes Portugal, Spain and Andorra), all main candidates in the district were aware and against the taxation of French citizens in Monaco, at least for those who were born in Monaco. The right-wing candidate, who was more strongly against French taxation in Monaco, received 82% of the vote in Monaco itself, but the socialist candidate won in the district and was elected. Still, he also declared that reforming the taxation of French citizens in Monaco will be one of his priorities.
Links (in French):
http://www.senat.fr/seances/s201201/s20120124/s20120124003.html#par_277
http://www.monacohebdo.mc/8623-laurence-sailliet%E2%80%89-%C2%AB%E2%80%89changer-l%E2%80%99image-des-francais-de-monaco%E2%80%89%C2%BB
http://www.monacohebdo.mc/8977-quel-depute-pour-monaco
http://www.monacohebdo.mc/9238-%C2%AB%E2%80%89tisser-une-relation-de-confiance-avec-les-francais-de-monaco%E2%80%89%C2%BB
If the French citizens in Monaco, who are only about 10,000 people, and a small minority even in their own district, are able to make so much noise, why don’t the 6 million Americans abroad complain more to their congressmen, and why doesn’t Congress pay attention to them?
Thanks, Shadow Raider for all the work you’re doing.
Senator Kay Bailey Hutchison (R-TX) and John Cornyn (R-TX) are also against FATCA, if you want to add them to your list. They’re one of the few who expressed their concern to Geithner about reciprocity.
http://www.bakerlaw.com/files/Uploads/Documents/FATCA/Comment%20Letters/Treasury_Department_Hutchison_04282011.pdf
A staff member at Hutchison’s office called me back in response to my letter.
I’ve also been raising awareness with a local state representative candidate, who said will have a meeting with bank associations. He said he would raise the issue and see what their response is. But at the state level, he said there’s not much they can do against a federal law that impacts local business, except contact the senators.