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WBA Compliance Center

The WBA Compliance Center is designed to highlight the services your bank can use to stay on top of the various compliance issues you will soon be facing.

The recently passed federal financial regulatory reform bill (Dodd-Frank Wall Street Reform and Consumer Protection Act) will deeply affect the future of the banking industry in Wisconsin. It has been conservatively estimated that the Dodd-Frank bill will generate 5,000 pages of new rules. Banks will be subject to at least 30 new or expanded regulations as a result of the enactment of the most sweeping rewrite of banking laws since the Great Depression. This will add to banks’ already high compliance costs and limit revenue opportunities.

Let WBA help you. Use the resources listed on this page to keep your compliance issues under control.


FFIEC Supplemental Guidance

The Federal Financial Institutions Examination Council (FFIEC) recently issued a supplement to the Authentication in an Internet Banking Environment guidance, issued in October 2005. The purpose of the supplement is to reinforce the risk-management framework described in the original guidance and update the FFIEC member agencies' supervisory expectations regarding customer authentication, layered security, and other controls in the increasingly hostile online environment.

The supplement stresses the need for performing risk assessments, implementing effective strategies for mitigating identified risks, and raising customer awareness of potential risks, but does not endorse any specific technology for doing so. The FFIEC member agencies will continue to work closely with financial institutions to promote security in electronic banking and have directed examiners to formally assess financial institutions under the enhanced expectations outlined in the supplement beginning in January 2012.

Read the FFIEC Guidance on Internet Banking Authentication.

DFI Changes Letter 40

In direct response to bankers’ questions during the roundtable sessions held by DFI over the last several months with the industry, and as a result of the subsequent advocacy efforts by WBA and CBW, DFI reissued Banking Letter 40 related to loans on nonaccrual. The revised Banking Letter 40 is effective as of May 10, 2012, the date of its issuance. DFI made significant helpful changes for state-chartered banks in this revised letter most notably in the provisions related to allowing for the return of loans to accrual status. WBA and CBW appreciate DFI’s prompt action in response to bankers’ concerns. Bankers should carefully review the revised letter to understand its full impact on your specific institutions. Copies of the DFI letter were mailed by DFI to each state-chartered bank and can also be found here.


Latest Compliance News
CFPB pursuing e-closing pilot
Apr. 24, 2014
The CFPB has announced plans for bringing technology to bear on the complexities and challenges of the home mortgage closing process.
FRB publishes G.20 finance report
Apr. 22, 2014
The FRB has published the February 2014 G.20 Finance Companies report.
FDIC updates weekly national rates and rate caps
Apr. 22, 2014
The FDIC has published its updated weekly national rates and rate caps.
FDIC proposes to rescind regulations
Apr. 21, 2014
The FDIC published today a proposed rule that would rescind and remove transitional regulations at 12 CFR Part 390, subparts B, C, D,...
FFIEC posts updated large institution CRA exam procedures
Apr. 21, 2014
The FFIEC has posted an update for the large institution CRA examination procedures to reflect changes to the Interagency Q&A regarding...
CFPB publishes completion guide for integrated disclosures
Apr. 18, 2014
The CFPB has released a new guide that is a compilation of instructions for completing the two new integrated TILA-RESPA disclosures...
Read more in the archive
Interchange Fee Small Issuer Exemption

The FRB has published lists of institutions that will be subject to, and exempt from, the debit card interchange fee standards in Regulation II. The statute exempts any debit card issuer that, together with its affiliates, has assets of less than $10 billion. The lists have been generated from the set of institutions in existence on Dec. 31, 2010, according to available data. The lists, available in Excel .XLS and .CSV format or as .PDF documents, will be updated annually.

Derivative Transactions Allowed for WI Banks

The Dodd-Frank Act, effective Jan. 21, 2013, prohibits state chartered banks from engaging in derivative transactions unless the lending limit law within the state allows it. John Knight, Boardman & Clark, llp, on behalf of WBA and its membership, negotiated an interpretation of Wisconsin law such that the existing use of the terms “liabilities” and “extension of credit” are broad enough to include derivatives. Effective Jan. 21, 2013, the Division of Banking will consider the credit exposure of derivative transactions when computing lending limits under the provisions of ss. 214.54 and 221.0320, Wis. Stats. The Department of Financial Institutions sent notices to all bank CEOs in Wisconsin on this interpretation and a copy may be found here.

IRS Backs Down from Position on ORE Carrying Costs

This past week, the IRS began notifying several banks under audit of a change in the IRS’ position related to ORE carrying costs according to information provided for WBA members by Wipfli. The IRS’ former position required banks to capitalize all carrying costs incurred for tax purposes, resulting in a tax deduction for these costs at the time the property was sold. The industry position has always been that these costs should not be capitalized for tax purposes and should be deducted as incurred. The IRS issued a blanket requirement last year mandating this adjustment on all bank audits (subject somewhat to materiality). Many banks have agreed to this adjustment on their IRS audit because it is a timing difference with a relatively short turn-around time. We are aware of four larger banks who did not agree to the adjustment on exam, and who decided to take the issue to the IRS appeal level. The IRS has a new industry leader who reviewed the bank position, and based on several notifications received last week, has “informally” abandoned this particular issue. Going forward, this should no longer be an issue on IRS audits of banks. An IRS memo on this topic can be found here.


At WBA’s request, six regulatory agencies supplied Wisconsin’s banks with a bird’s eye view of today’s banking industry. As a result, the six articles contained in this insert will give you the regulators’ perspective on issues ranging from “Too Big To Fail” to specific examination concerns like real estate appraisals and concentration risk. Read the WBA Regulator Review.

Strategic Planning for Community Banks: M&A and Capital Raises

Download the full article from Boardman & Clark LLP, "Strategic Planning for Community Banks: M&A and Capital Raises."

For more information on strategic planning, view and/or download the materials for the WBA Executive Briefing:

Materials| Extra Slides

WBA Basel III Resource Center

The WBA has collected a variety of resources regarding Basel III in our WBA Basel III Resource Center. This members only password protected area of our site will continue to be updated as we receive information on Basel III so please be sure to frequently check the page. Members can visit the page at

The FDIC also released a variety of resources that can be found at .

Compliance Toolkits

As part of an ongoing effort to assist members with compliance efforts, WBA is adding a variety of compliance toolkits to its collection.

The latest is the WBA Third-Party Securities Networking Relationships Toollkit. Available free of charge, this toolkit, created by the Boardman Law Firm, details what bankers should know about broker-dealers providing services on bank premises.

Download any the kits below by clicking here.

WBA Third-Party Securities Networking Relationships Toolkit

WBA Executive & Incentive Compensation Toolkit

WBA FDIC Insurance Changes for Noninterest-bearing Transaction Accounts Toolkit

WBA SAFE Act Toolkit

WBA Dodd-Frank Toolkit

WBA Compliance Journal

The WBA Compliance Journal is intended to provide accurate information in regard to the subject matter covered as of the date of publication; however, the information does not constitute legal advice. Click to read a preview of the latest issue of the WBA Compliance Journal.

Legal Q&A

The information provided in these articles is not intended to provide legal advice; rather, it is intended to provide general information about banking issues. Consult your institution’s attorney for special legal advice or assistance. Read Legal Q&A articles.

WBA Models

Model Pandemic Influenza Plan available
(Updated June 2009 with information on the H1N1 flu virus, and more)
Given the need for financial institutions to create a plan, WBA has prepared a model pandemic influenza plan for WBA members. The model is designed to be used on its own or as part of an institution's broader disaster recovery plan. Since the plan is intended as a model only, it must be customized by each financial institution to their specific situation prior to its implementation and use. Download the model here.

Education Opportunities
WBA Forms

WBA forms offered by FIPCO have been accepted as standard by bank regulatory agencies, attorneys and the Wisconsin judiciary. In conjunction with legal counsel, these forms are developed and reviewed and constantly updated by the WBA Drafting Team, helping to ensure compliance with State and Federal regulations.


Electronic Forms
Electronic files of commonly used WBA forms are available in various formats. These WBA form images are available using Microsoft® Word, Adobe Reader or other third party software systems. The images, or eForms, can be electronically filled out and printed.

WBA Hard Copy Forms
Over 430 forms relating to consumer, real estate, commercial, agricultural and municipal loans; deposit accounts; safe deposit boxes; and deposit and operations are available. Forms are purchased by financial institutions, dealerships, attorneys and realtors.

More information is available here. For more information contact FIPCO Sales.

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