The below article is the Special Focus section of the June 2019 Compliance Journal. The full issue may be viewed by clicking here.

The Wisconsin Consumer Act (WCA) continues to be a frequent topic for the WBA legal call program. We have compiled some of the most frequently asked WCA questions and present them in the article below. Note that this article is not, nor intended to be, a recital of all applicable State and Federal laws and regulations for specific transactions.

What transactions does the WCA cover?

The WCA applies to loans and credit sales to individuals for personal, family, or household purpose when the amount financed is $25,000 or less and the loan is not secured by a first lien real estate mortgage or equivalent security interest. 

Note the exception for an “equivalent security interest,” sometimes referred to as a “1st lien equivalent.” The concept of a “1st lien equivalent” is unique to Wisconsin. For example, Bank A takes a 1st lien mortgage on a purchase. The customer returns to Bank A for a line of credit, and Bank A secures the line with another lien on the same property. If there is no intervening creditor, that additional lien is effectively a 1st lien equivalent. On the other hand, if that customer comes back to Bank A for a line of credit, and at that time there is an intervening creditor who has taken a lien on the same property sometime after Bank A took the 1st lien on the purchase, Bank A’s new lien for the line of credit would be “true junior mortgage” rather than a 1st lien equivalent.

Does the WCA give the ability to prepay?

Yes. The WCA provides the consumer the right to prepayment in full or part at any time without penalty. 

Are deferral fees permitted by the WCA?

Not for simple-interest transactions. Under the WCA deferral fees are permitted for precomputed transactions but they are not permitted for simple-interest transactions. 

Does the WCA impose maximum rates of finance charges? 

No. The creditor and customer may agree to a maximum finance charge per the terms of the contract. However, the rate may not be unconscionable. 

Does the WCA restrict how interest is calculated? 

No. However, if the 1/360th method is utilized, it must be disclosed conspicuously. 

Does the WCA restrict rates after default? 

Yes. The interest rate after the final scheduled maturity date may not exceed the greater of 12% per year or the annual rate of finance charge assessed on the transaction. 

Does the WCA require a right to cure default?

Yes. The WCA prohibits a bank from taking any action with respect to default until notice requirements have been met. The notice must be given to the customer, and inform them how to cure the default.

Does the WCA have requirements for delinquency charges? 

Yes. For closed-end transactions, late charges are restricted to the lesser of $10 or 5% of the unpaid amount of the installment. 

The Wisconsin Department of Financial Institutions has explained that an installment is considered current when a payment is made on its due date or within the 10 days following its due date, creating a grace period. 

If an installment is received on or before its scheduled or deferred due date, no delinquency charge may be assessed for that payment even though an earlier installment or delinquency charge has not been paid in full. 

A delinquency charge may be collected only once on any installment. 

When assessing late charges, the WCA requires payments be applied first to current installments and then to delinquent installments. 

Finally, if interest is charged after the final scheduled maturity date, no delinquency charge may be assessed on the final scheduled payment. 
For open-end credit, there is no limit on the amount nor a grace period, but the charge must still be agreed to by contract. 

What are some of the requirements for variable rate loans under the WCA? 

There are two types of variable rate transactions under the WCA: approved index loans and non-approved index loans. 

For approved index loans: 

  • Adjustments in rate are based upon changes in an approved index (e.g. Wall Street Journal Prime).
  • Index approved by the Secretary of WDFI. 
  • Index must be beyond control of creditor. 
  • Index must be verifiable by consumer.
  • Limitations on decreases allowed only if similar limitations placed on increases.
  • No carry-over provision.

For non-approved index loans: 

  • Index is set by the creditor and is not tied to an approved index.
  • Additional limitations and disclosure requirements, including: 
  • May not increase rate during first 3 months following consummation of transaction.
  • Rate increases may not exceed 2% per year.

Are there subsequent notice requirements for variable rate closed-end loans under the WCA? 

Yes. A creditor must mail or deliver a written notice of every rate change at least 15 days prior to the change in rate if implemented by a change in periodic payment, other than the final payment. The notice must be given no later than 30 days after any other change. 

Notice is not required, however, for closed-end loans if the rate change is based on an approved index and there is no change in the periodic payment (other than the final payment). 

Are there subsequent notice requirements for variable rate open-end loans under the WCA? 

No notice is required if the adjustment is made in a variable rate transaction pursuant to an open-end credit plan that is based upon changes in an approved index. 

Does the WCA require any notices to customers, co-signers, and guarantors? 

Yes. The creditor must furnish the customer with an exact copy of each instrument, document, agreement and contract signed by the customer and which evidences the customer’s obligation before any payment is due to the creditor. The creditor must also provide the customer with copies of every writing evidencing the customer’s obligation to pay upon request of the customer. One such copy must be furnished at no charge to the customer. Subsequent copies must also be furnished, but the creditor may charge a reasonable fee for production and delivery. 

Each person signing the guaranty or as co-signer in addition to signing the guaranty or note must receive either: copies of each instrument, document, agreement, and contract signed by the customer and which evidences the customer’s obligation, or an explanation of personal obligation. A sample notice appears in the WCA and is reproduced on the WBA 156 or 156A (for open-end credit) Explanation of Personal Obligation forms. 

In connection with open-end credit, if any subsequent change would increase or extend con-tingent liability of the guarantor or co-signer, an explanation of change must be provided conspicuously disclosing that if such person wishes to terminate liability with respect to future transactions, that person must notify the creditor in writing.

Conclusion

While this article is not comprehensive in its consideration of all WCA issues, WBA hopes it will serve as a helpful guide to some of the more common questions we receive. For a full understanding of the applicable rules WBA recommends consulting Chapters 421 through 427 of the Wisconsin Statutes for the full scope of the WCA. 

By, Ally Bates

The below article is the Compliance Notes section of the June 2019 Compliance Journal. The full issue may be viewed by clicking here.

FDIC issued the June 2019 Consumer Compliance Supervisory Highlights. The publication is intended to provide supervised institutions and the public with information and observations related to the FDIC’s consumer compliance supervision activities in 2018. The report may be viewed at: https://www.fdic.gov/regulations/examinations/consumercomplsupervisoryhighlights.pdf


OFAC imposed sanctions on an Iraq-based Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF) financial conduit, South Wealth Resources Company (SWRC), which has trafficked hundreds of millions of dollars’ worth of weapons to IRGC-QF-backed Iraqi militias.  SWRC and its two Iraqi associates, who are also being designated, have covertly facilitated the IRGC-QF’s access to the Iraqi financial system to evade sanctions. SWRC and its two associates are being designated as Specially Designated Global Terrorists pursuant to Executive Order 13224, which targets terrorists and those providing support to terrorists or acts of terrorism. The notice may be viewed at: https://home.treasury.gov/news/press-releases/sm706


FRB released 2019 Minority Owned Depository Institutions Data. The data may be viewed at: https://www.federalreserve.gov/releases/mob/current/default.htm


FRB has released its list of insured U.S.-chartered commercial banks with consolidated assets of $300 million or more as of March 31, 2019. There are 1,835 banks on the list, with total consolidated assets of $16.33 trillion. The list may be viewed at: https://www.federalreserve.gov/releases/lbr/current/default.htm


CFPB announced its first symposium will be held on June 25 at 9 a.m. The symposium, part of a series announced earlier this year, will focus on the Dodd-Frank Act’s prohibition on abusive acts or practices. The symposium will be webcast on CFPB’s website. The announcement may be viewed at: https://www.consumerfinance.gov/about-us/newsroom/cfpb-hold-first-symposium-june-25/


FRB posted the April 2019 G.19 Consumer Credit Data. In April, consumer credit increased at a seasonally adjusted annual rate of 5-1/4 percent. Revolving credit increased at an annual rate of 8 percent, while nonrevolving credit increased at an annual rate of 4-1/4 percent. The notice may be viewed at: https://www.federalreserve.gov/releases/g19/current/default.htm 


FCC voted to make clear that voice service providers may aggressively block unwanted robocalls before they reach consumers. Specifically, FCC approved a Declaratory Ruling to affirm that voice service providers may, as the default, block unwanted calls based on reasonable call analytics, as long as their customers are informed and have the opportunity to opt out of the blocking. The announcement may be viewed at: https://docs.google.com/viewer?url=https%3A%2F%2Fdocs.fcc.gov%2Fpublic%2Fattachments%2FDOC-357852A1.pdf


FTC provided its annual enforcement report to CFPB regarding FTC’s enforcement activities related to compliance with Regulation Z (the Truth in Lending Act or TILA); Regulation M (the Consumer Leasing Act or CLA); and Regulation E (the Electronic Fund Transfer Act or EFTA). The report may be viewed at: https://www.ftc.gov/system/files/documents/reports/ftc-enforcement-activities-related-compliance-regulation-z-truth-lending-act-regulation-m-consumer/cfpb_2018_report_re_tila_and_cla_and_efta.pdf


NCUA has released data on the financial performance of federally insured credit unions for the quarter ending March 31, 2019. NCUA’s Quarterly Data Summary Reports include an overview of the quarterly Call Report data as well as tables showing the recent history of major credit union performance indicators. The data may be viewed at: https://www.ncua.gov/files/publications/analysis/quarterly-data-summary-2019-Q1.pdf


FHFA has launched the new Uniform Mortgage-Backed Security (UMBS), which combines the separate Fannie Mae and Freddie Mac To-Be-Announced markets into one. The FHFA’s statement may be viewed at: https://www.fhfa.gov/Media/PublicAffairs/Pages/Statement-of-FHFA-Deputy-Director-Robert-Fishman-on-the-launch-of-the-new-Uniform-Mortgage-Backed-Security.aspx


CFPB has published an article for consumers on how to avoid mortgage closing scams. The FBI has reported that scammers are increasingly taking advantage of homebuyers during the closing process. Through a sophisticated phishing scam, they attempt to divert your closing costs and down payment into a fraudulent account by confirming or suggesting last-minute changes to your wiring instructions. In fact, reports of these attempts have risen 1,100 percent between 2015 and 2017, and in 2017 alone, there was an estimated loss of nearly $1 billion in real estate transaction costs. The article and tools for avoiding the scam may be viewed at: https://www.consumerfinance.gov/about-us/blog/mortgage-closing-scams-how-protect-yourself-and-your-closing-funds/   


CFPB released the latest quarterly consumer credit trends report, which explores the relationship between fluctuations in consumers’ credit scores and the timing of consumers’ applications for credit. The ability of consumers to access various types of credit can be affected by their credit scores, as many lenders require a minimum credit score before credit will be extended. Given the critical role that credit scores play in determining access to credit, there has been a push in recent years to make credit scores more available to consumers and to educate them on how their scores are used and calculated. The report may be viewed at: https://files.consumerfinance.gov/f/documents/cfpb_consumer-credit-trends_timing-applications-consumer-credit_2019-05.pdf


OFAC released its annual Terrorist Assets Report to Congress concerning the nature and extent of assets held in the United States by terrorism-supporting countries and organizations engaged in international terrorism. The report may be viewed at: https://www.treasury.gov/resource-center/sanctions/Programs/Documents/tar2018.pdf


The Military Lending Act’s website recently made significant changes to enhance security of the site and better protect the personal information of Service members. All users of the site will be required to create user accounts. A user account will be required to access both the Single Record Request and the Multiple Record Request capabilities of the MLA website. No search for active service on the MLA website will be possible without a user account. The announcement may be viewed at: https://mla-ap.dmdc.osd.mil/mla/#/news


HUD announced it is awarding an additional $1.2 million under its Fair Housing Initiatives Program (FHIP) to support the efforts of 11 organizations to educate the public and housing providers about their rights and responsibilities under the Fair Housing Act. The announcement may be viewed at: https://www.hud.gov/press/press_releases_media_advisories/HUD_No_19_084


Treasury announced the creation of a Financial Innovation Partnership with the United Kingdom’s HM Treasury. The partnership aims to build on and deepen bilateral engagement on emerging trends in financial services innovation.  This will include encouraging collaboration in the private sector, sharing information and expertise about regulatory practices, and promoting growth and innovation. The announcement may be viewed at: https://home.treasury.gov/news/press-releases/sm698


FDIC issued a reminder about the Summary of Deposits Survey, the annual survey of branch office deposits as of June 30 for all FDIC-insured institutions, including insured U.S. branches of foreign banks. All institutions with branch offices are required to submit the survey; institutions with only a main office are exempt. All survey responses are required by July 31, 2019. No filing extensions will be granted. The notice may be viewed at: https://www.fdic.gov/news/news/financial/2019/fil19028.html


FRB, FDIC, and OCC issued the host state loan-to-deposit ratios that they will use to determine compliance with section 109 of the Riegle-Neal Interstate Banking and Branching Efficiency Act of 1994. These ratios replace the prior year’s ratios, which were released on June 15, 2018. The notice may be viewed at: https://www.federalreserve.gov/newsevents/pressreleases/bcreg20190528a.htm.


OCC issued the updated “Foreword” booklet of the Comptroller’s Handbook. The booklet describes the overall organization and format of the Comptroller’s Handbook. The booklet may be viewed at: https://www.occ.gov/publications/publications-by-type/comptrollers-handbook/foreword/pub-ch-foreword.pdf 


FRB’s latest Report on the Economic Well-Being of U.S. Households found that most measures of economic well-being and financial resilience in 2018 were similar to, or slightly better than, those in 2017. Overall, the financial experiences reported by the 11,000 adults surveyed in 2018 were largely positive, and many families have experienced substantial gains since the survey began in 2013, in line with the nation’s ongoing economic expansion. When asked about their overall economic well-being, 75 percent of U.S. adults said they were “doing okay” or “living comfortably”—up 12 percentage points from 2013.  The full report may be viewed at: https://www.federalreserve.gov/publications/files/2018-report-economic-well-being-us-households-201905.pdf


FDIC has resolved a lawsuit with Advance America, Cash Advance Centers, Inc.; Check Into Cash, Inc.; and Northstate Check Exchange. Advance America et al. v. Federal Deposit Insurance Corporation et al. (D.D.C.). The lawsuit had alleged terminations of payday lender bank accounts. In exchange for the plaintiffs’ agreement to dismiss the lawsuit, the FDIC is issuing: (1) a statement summarizing its longstanding policies and guidance regarding the circumstances in which the FDIC recommends that a financial institution terminate a customer’s deposit account and reiterating preexisting public guidance to financial institutions about providing banking services and carrying out Bank Secrecy Act obligations; and (2) a cover letter transmitting the statement to the plaintiffs that reiterates prior correspondence from the FDIC Chairman, summarizes applicable FDIC policy, and notes that the FDIC is conducting additional training of its workforce. FDIC’s accompanying statement may be viewed at: https://www.fdic.gov/news/news/press/2019/pr19040a.pdf


CFPB published an article regarding research that showed that veterans, similarly to servicemembers, experience somewhat higher levels of financial well-being than non-veterans. The article may be viewed at: https://www.consumerfinance.gov/about-us/blog/servicemembers-exhibit-higher-levels-financial-well-being-us-population/


OCC issued its Semiannual Risk Perspective which addresses key issues facing banks, focusing on those that pose threats to the safety and soundness of banks and their compliance with applicable laws and regulations. The report may be viewed at: https://www.occ.gov/publications/publications-by-type/semiannual-risk-perspective/pub-semiannual-risk-perspective-spring-2019.pdf


FATF issued its May 2019 Business Bulletin which provides a brief update on recent FATF outcomes of interest to the private sector, including those of the 2019 FATFPrivate Sector Consultative Forum and the FATF/MONEYVALJoint Experts’ meeting. The bulletin may be viewed at: http://www.fatf-gafi.org/media/fatf/documents/FATF-Business-Bulletin-May-2019.pdf 

By, Ally Bates

The below article is the Regulatory Spotlight section of the June 2019 Compliance Journal. The full issue may be viewed by clicking here.

Agencies Finalize Liquidity Coverage Ratio Rule.

The Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) are jointly adopting as a final rule, without change, the 08/31/2018, interim final rule, which amended the agencies’ liquidity coverage ratio (LCR) rule to treat liquid and readily-marketable, investment grade municipal obligations as high-quality liquid assets. This treatment was mandated by section 403 of the Economic Growth, Regulatory Relief, and Consumer Protection Act. The final rule is effective 07/05/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-06-05/pdf/2019-11715.pdf. Federal Register, Vol. 84, No. 108, 06/05/2019, 25975-25978.

Agencies Propose Amendments to Resolution Plans Required.

The Board of Governors of the Federal Reserve System (FRB), and the Federal Deposit Insurance Corporation (FDIC) are inviting comment on a proposal to amend and restate the jointly issued regulation (the Rule) implementing the resolution planning requirements of section 165(d) of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Dodd-Frank Act). The proposal is intended to reflect improvements identified since the Rule was finalized in November 2011 and to address amendments to the Dodd-Frank Act made by the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA). The proposed amendments to the Rule include a proposal by the Board to establish risk-based categories for determining the application of the resolution planning requirement to certain U.S. and foreign banking organizations, consistent with section 401 of EGRRCPA, and a proposal by the agencies to extend the default resolution plan filing cycle, allow for more focused resolution plan submissions, and improve certain aspects of the Rule. Comments are due 06/21/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-14/pdf/2019-08478.pdf. Federal Register, Vol. 84, No. 93, 05/14/2019, 21600-21631.

Agencies Propose Amendments to Applicability Thresholds for Regulatory Capital Requirements.

The Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) are inviting comment on a proposal that would determine the application of regulatory capital requirements to certain U.S. intermediate holding companies of foreign banking organizations and their depository institution subsidiaries and the application of standardized liquidity requirements with respect to certain U.S. operations of large foreign banking organizations and certain of their depository institution subsidiaries, each according to risk-based categories. For liquidity, the proposal would require a foreign banking organization that meets certain criteria to comply with liquidity coverage ratio and net stable funding ratio requirements with respect to any U.S. intermediate holding company and certain depository institution subsidiaries thereof; in addition, FRB is not proposing but is requesting comment on whether it should impose standardized liquidity requirements on such foreign banking organizations with respect to their U.S. branch and agency networks, as well as possible approaches for doing so. The proposal is consistent with a separate proposal issued by FRB that would apply certain prudential standards to foreign banking organizations based on the same categories, and is similar to a proposal issued by the agencies in 2018 that would determine the application of regulatory capital and standardized liquidity requirements for large U.S. banking organizations according to risk-based categories (the domestic interagency proposal). In addition, FRB is modifying one aspect of the proposed requirements under the domestic interagency proposal with respect to certain banking organizations; specifically, to propose the application of a standardized liquidity requirement to certain U.S. depository institution holding companies that meet specified criteria relating to their liquidity risk profile. The agencies are also making technical amendments to certain provisions of the domestic interagency proposal. Comments are due 06/21/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-24/pdf/2019-09245.pdf. Federal Register, Vol. 84, No. 101, 05/24/2019, 23991-24007.

CFPB Proposes Amendments to Regulation C.

The Bureau of Consumer Financial Protection (CFPB) is proposing two alternatives to amend Regulation C to increase the threshold for reporting data about closed-end mortgage loans so that institutions originating fewer than either 50 closed-end mortgage loans, or alternatively 100 closed-end mortgage loans, in either of the two preceding calendar years would not have to report such data as of 01/01/2020. The proposed rule would also adjust the threshold for reporting data about open-end lines of credit by extending to 01/01/2022, the current temporary threshold of 500 open-end lines of credit and setting the threshold at 200 open-end lines of credit upon the expiration of the proposed extension of the temporary threshold. CFPB is also proposing to incorporate into Regulation C the interpretations and procedures from the interpretive and procedural rule that CFPB issued on 08/31/2018, and to implement further section 104(a) of the Economic Growth, Regulatory Relief, and Consumer Protection Act. Comments are due 06/12/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-13/pdf/2019-08983.pdf. Federal Register, Vol. 84, No. 92, 05/13/2019, 20972-21041.

CFPB Proposes Amendments to Debt Collection Practices.

CFPB proposes to amend Regulation F, 12 CFR part 1006, which implements the Fair Debt Collection Practices Act (FDCPA) and currently contains the procedures for State application for exemption from the provisions of the FDCPA. CFPB’s proposal would amend Regulation F to prescribe Federal rules governing the activities of debt collectors, as that term is defined in the FDCPA. CFPB’s proposal would, among other things, address communications in connection with debt collection; interpret and apply prohibitions on harassment or abuse, false or misleading representations, and unfair practices in debt collection; and clarify requirements for certain consumer-facing debt collection disclosures. Comments are due 08/19/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-21/pdf/2019-09665.pdf. Federal Register, Vol. 84, No. 98, 05/21/2019, 23274-23418.

CFPB Publishes Plan for Review of Rules.

CFPB is publishing a plan for the review of rules which have or will have a significant economic impact upon a substantial number of small entities, pursuant to section 610 of the Regulatory Flexibility Act. Comments are due 07/15/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-15/pdf/2019-09813.pdf. Federal Register, Vol. 84, No. 94, 05/15/2019, 21732-21733.

CFPB Requests Comment on Overdraft Rule.

CFPB is conducting a review of the Overdraft Rule consistent with section 610 of the Regulatory Flexibility Act. As part of this review, the Bureau is seeking comment on the economic impact of the Overdraft Rule on small entities. These comments may assist the Bureau in determining whether the Overdraft Rule should be continued without change, or amended or rescinded to minimize any significant economic impact of the rules upon a substantial number of such small entities, consistent with the stated objectives of applicable statutes. Comments are due 07/01/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-15/pdf/2019-09812.pdf. Federal Register, Vol. 84, No. 94, 05/15/2019, 21729-21732.

CFPB Requests Comment on Information Collections.

  • CFPB announced it seeks comment on the information collection titled Policy to Encourage Trial Disclosure Programs. CFPB also gave notice that it sent the collection to OMB for review. Comments are due 07/12/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-13/pdf/2019-09720.pdf. Federal Register, Vol. 84, No. 92, 05/13/2019, 20864.
  • CFPB announced it seeks comment on the information collection titled Equal Access to Justice Act. CFPB also gave notice that it sent the collection to OMB for review. Comments are due 07/12/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-13/pdf/2019-09723.pdf. Federal Register, Vol. 84, No. 92, 05/13/2019, 20864-20865.
  • CFPB announced it seeks comment on the information collection titled Truth In Lending Act (Regulation Z) 12 CFR 1026. CFPB also gave notice that it sent the collection to OMB for review. Comments are due 07/29/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-28/pdf/2019-10972.pdf. Federal Register, Vol. 84, No. 102, 05/28/2019, 24498-24499.
  • CFPB announced it seeks comment on the information collection titled Report of Terms of Credit Card Plan. CFPB also gave notice that it sent the collection to OMB for review. Comments are due 06/28/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-29/pdf/2019-11185.pdf. Federal Register, Vol. 84, No. 103, 05/29/2019, 24764. 
  • CFPB announced it seeks comment on the information collection titled Equal Credit Opportunity Act (Regulation B) 12 CFR 1002. CFPB also gave notice that it sent the collection to OMB for review. Comments are due 06/28/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-29/pdf/2019-11186.pdf. Federal Register, Vol. 84, No. 103, 05/29/2019, 24763-24764.
  • CFPB announced it seeks comment on the information collection titled Regulation I: Disclosure Requirements for Depository Institutions Lacking Federal Deposit Insurance. CFPB also gave notice that it sent the collection to OMB for review. Comments are due 08/06/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-06-07/pdf/2019-12005.pdf. Federal Register, Vol. 84, No. 110, 06/07/2019, 26652-26653.

FRB Proposes Amendments to Control and Divestiture Proceedings.

The Board of Governors of the Federal Reserve System (FRB) is inviting public comment on a proposal that would revise FRB’s regulations related to determinations of whether a company has the ability to exercise a controlling influence over another company for purposes of the Bank Holding Company Act or the Home Owners’ Loan Act. The proposal would significantly expand the number of presumptions for use in such determinations. By codifying the presumptions in FRB’s Regulation Y and Regulation LL, FRB’s rules would provide substantial additional transparency on the types of relationships that FRB would view as supporting a determination that one company controls another company. The proposed presumptions generally would be consistent with FRB’s historical practice with respect to the types of relationships that raise, or do not raise, significant controlling influence concerns. Several of the proposed presumptions, however, would represent targeted adjustments relative to FRB’s historical practice. Finally, the proposal would include various definitions and ancillary rules to ensure that the application of the proposed presumptions is clear, transparent, and consistent. Comments are due 07/15/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-14/pdf/2019-09415.pdf. Federal Register, Vol. 84, No. 93, 05/14/2019, 21634-21666.

FRB Proposes Revisions to Prudential Standards.

FRB issued a proposed rule that would revise the framework for applying the enhanced prudential standards applicable to foreign banking organizations under section 165 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, as amended by the Economic Growth, Regulatory Relief, and Consumer Protection Act. The proposal would establish categories that would be used to tailor the stringency of enhanced prudential standards based on the risk profile of a foreign banking organization’s operations in the United States. The proposal also would amend certain enhanced prudential standards, including standards relating to liquidity, risk management, stress testing, and single-counterparty credit limits, and would make corresponding changes to reporting forms. The proposal would make clarifying revisions and technical changes to FRB’s 10/31/2018, proposal for large U.S. bank holding companies and certain savings and loan holding companies relating to FRB’s internal liquidity stress testing requirements and GSIB surcharge rule. Separately, FRB, the Office of the Comptroller of the Currency (OCC), and the Federal Deposit Insurance Corporation (FDIC) (together, the agencies) are requesting comment on a proposal to revise the applicability of the agencies’ capital and liquidity requirements for foreign banking organizations based on the same categories, and FRB is requesting comment on whether it should impose standardized liquidity requirements on the U.S. branch and agency network of a foreign banking organization, as well as possible approaches for doing so. In addition, FRB and FDIC are separately requesting comment on a proposal to revise the applicability of the resolution planning requirements applicable to large U.S. banking organizations and foreign banking organizations, using a category approach that is broadly consistent with the one set forth in the proposal. Comments are due 06/21/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-15/pdf/2019-07895.pdf. Federal Register, Vol. 84, No. 94, 05/15/2019, 21988-22036.

FRB Issues Potential Modifications of Payment Services.

FRB is requesting comment on potential modifications to the Federal Reserve Banks’ (Reserve Banks) payment services to facilitate adoption of a later same-day automated clearinghouse (ACH) processing and settlement window. Specifically, the Reserve Banks would extend the daily operating hours of the National Settlement Service (NSS) to allow the private-sector ACH operator to settle its in-network transactions resulting from the later same-day ACH window. To support these new NSS operating hours, the Reserve Banks would extend the daily operating hours of the Fedwire Funds Service, creating implications for extension policies for contingencies that might result in more frequent delays to the reopening of the Fedwire Funds Service. Finally, FRB is requesting comment on corresponding changes to the Federal Reserve Policy on Payment System Risk related to a new posting time and an increase to the daylight overdraft fee rate. Comments are due 07/15/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-16/pdf/2019-09949.pdf. Federal Register, Vol. 84, No. 95, 05/16/2019, 22123-22129.

FRB Repeals SAFE Act Regulations.

FRB is repealing its regulations that incorporated the Secure and Fair Enforcement for Mortgage Licensing Act (the S.A.F.E. Act). Title X of the Dodd-Frank Act transferred rulemaking authority for a number of consumer financial protection laws, including the S.A.F.E. Act, from FRB to the Bureau of Consumer Financial Protection (CFPB). In December 2011, the Bureau published an interim final rule, incorporating the S.A.F.E. Act into its Regulations G and H. In April 2016, CFPB finalized the interim final rule. Accordingly, FRB is repealing its S.A.F.E. Act regulations. The repeal is effective 06/14/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-15/pdf/2019-09948.pdf. Federal Register, Vol. 84, No. 94, 05/15/2019, 21691-21692.

FRB Requests Comment on Information Collections.

  • FRB announced it seeks comment on the information collection titled Recordkeeping Provisions Associated with the Interagency Statement on Complex Structured Finance Activities. FRB also gave notice that it sent the collection to OMB for review. Comments are due 07/15/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-15/pdf/2019-09962.pdf. Federal Register, Vol. 84, No. 94, 05/15/2019, 21778-21779.
  • FRB announced it seeks comment on the information collection titled Reporting, Recordkeeping, and Disclosure Requirements Associated with Regulation NN. FRB also gave notice that it sent the collection to OMB for review. Comments are due 07/16/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-17/pdf/2019-10246.pdf. Federal Register, Vol. 84, No. 96, 05/17/2019, 22494-22495.

FDIC Requests Comment on Information Collections.

  • The Federal Deposit Insurance Corporation (FDIC) announced it seeks comment on the information collection titled Interagency Complaint Form. FDIC also gave notice that it sent the collection to OMB for review. Comments are due 06/24/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-23/pdf/2019-10790.pdf. Federal Register, Vol. 84, No. 100, 05/23/2019, 23789-23790.
  • FDIC announced it seeks comment on the information collection titled Market Risk Capital Requirements. FDIC also gave notice that it sent the collection to OMB for review. Comments are due 06/24/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-23/pdf/2019-10795.pdf. Federal Register, Vol. 84, No. 100, 05/23/2019, 23790-23792.

FDIC Requests Comment on Technical Assistance Offerings and Delivery.

FDIC issued a request for information to seek public input on additional steps FDIC could take to support effective management and operation of FDIC-supervised institutions through technical assistance and collaboration on safety and soundness and consumer compliance matters. FDIC is seeking feedback from community banks, other FDIC-supervised institutions, and other interested parties on existing FDIC methods and efforts to provide technical assistance. FDIC requests input on strategies to improve the effectiveness of these offerings. FDIC also seeks comment on both the content and delivery method of various technical assistance offerings and on other steps FDIC could take to increase the level and effectiveness of technical assistance offered to the industry. Comments are due 08/06/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-06-07/pdf/2019-11911.pdfFederal Register, Vol. 84, No. 110, 06/07/2019, 26681-26683.

FDIC Appointed Receiver.

FDIC has been appointed the sole receiver for the financial institutions listed in the notice, effective as of the Date Closed as indicated in the listing. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-06-07/pdf/2019-12017.pdf. Federal Register, Vol. 84, No. 110, 06/07/2019, 26681.  

FDIC Issues Terminations of Receiverships.

FDIC as Receiver for former depository institutions, intends to terminate its receivership for the institutions listed in the notices. The liquidation of the assets for each receivership has been completed. To the extent permitted by available funds and in accordance with law, the Receiver will be making a final dividend payment to proven creditors. Based upon the foregoing, the Receiver has determined that the continued existence of the receiverships will serve no useful purpose. Consequently, notice is given that the receiverships shall be terminated, to be effective no sooner than thirty days after the date of this notice. If any person wishes to comment concerning the termination of any of the receiverships, such comment must be made in writing, identify the receivership to which the comment pertains, and be sent within thirty days of the date of this notice to: Federal Deposit Insurance Corporation, Division of Resolutions and Receiverships, Attention: Receivership Oversight Department 34.6, 1601 Bryan Street, Dallas, TX 75201. No comments concerning the termination of the above-mentioned receiverships will be considered which are not sent within this time frame. The notices may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-24/pdf/2019-10868.pdf. Federal Register, Vol. 84, No. 101, 05/24/2019, 24142.

OCC Finalizes Rule on Home Owners’ Loan Act.

The Office of the Comptroller of the Currency (OCC) is issuing a final rule to implement a new section of the Home Owners’ Loan Act (HOLA). The Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) amended HOLA to add a new section that allows a Federal savings association with total consolidated assets equal to or less than $20 billion, as reported by the association to the Comptroller as of 12/31/2017, to elect to operate as a covered savings association. A covered savings association has the same rights and privileges as a national bank and is subject to the same duties, restrictions, penalties, liabilities, conditions, and limitations as a national bank. A covered savings association retains its Federal savings association charter and existing governance framework. The new section of HOLA requires OCC to issue rules that, among other things, establish streamlined standards and procedures for elections to operate as covered savings associations and clarify requirements for the treatment of covered savings associations. The rule is effective 07/01/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-24/pdf/2019-10902.pdf. Federal Register, Vol. 84, No. 101, 05/24/2019, 23991-24007.

OCC Requests Comment on Information Collections.

  • OCC announced it seeks comment on the information collection titled Regulation C—Home Mortgage Disclosure. OCC also gave notice that it sent the collection to OMB for review. Comments are due 06/19/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-20/pdf/2019-10441.pdf. Federal Register, Vol. 84, No. 97, 05/20/2019, 22935-22936.
  • OCC announced it seeks comment on the information collections titled Regulation E— Electronic Fund Transfer Act and Regulation Z—Truth in Lending Act. OCC also gave notice that it sent the collections to OMB for review. Comments are due 07/19/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-20/pdf/2019-10434.pdf. Federal Register, Vol. 84, No. 97, 05/20/2019, 22931-22933.
  • OCC announced it seeks comment on the information collections titled Survey of Minority Owned Institutions. OCC also gave notice that it sent the collections to OMB for review. Comments are due 06/19/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-20/pdf/2019-10442.pdf. Federal Register, Vol. 84, No. 97, 05/20/2019, 22936-22937.
  • OCC announced it seeks comment on the information collections titled Consumer Protections for Depository Institution Sales of Insurance. OCC also gave notice that it sent the collections to OMB for review. Comments are due 06/24/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-24/pdf/2019-10831.pdf. Federal Register, Vol. 84, No. 101, 05/24/2019, 24199-24201.
  • OCC announced it seeks comment on the information collections titled Interagency Statement on Complex Structured Finance Transactions. OCC also gave notice that it sent the collections to OMB for review. Comments are due 06/24/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-24/pdf/2019-10832.pdf. Federal Register, Vol. 84, No. 101, 05/24/2019, 24198-24199.
  • OCC announced it seeks comment on the information collections titled Domestic First Lien Residential Mortgage Data. OCC also gave notice that it sent the collections to OMB for review. Comments are due 06/27/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-28/pdf/2019-11051.pdf. Federal Register, Vol. 84, No. 102, 05/28/2019, 24596-24597.

OCC Issues Correction to Information Collection.

OCC announced it seeks comment on the information collections titled Securities Exchange Act Disclosure Rules and Securities of Federal Savings Associations. The notice was first issued in the Federal Register on 03/29/2019. It is being reissued to correct an error in the burden estimates.  OCC also gave notice that it sent the collections to OMB for review. Comments are due 06/19/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-20/pdf/2019-10443.pdf. Federal Register, Vol. 84, No. 97, 05/20/2019, 22933-22934.

HUD Issues Debenture Interest Rates.

The Department of Housing and Urban Development (HUD) announced changes in the interest rates to be paid on debentures issued with respect to a loan or mortgage insured by the Federal Housing Administration (FHA) under the provisions of the National Housing Act (the Act). The interest rate for debentures issued under Section 221(g)(4) of the Act during the 6-month period beginning 01/01/2019, is 3.125 percent. The interest rate for debentures issued under any other provision of the Act is the rate in effect on the date that the commitment to insure the loan or mortgage was issued, or the date that the loan or mortgage was endorsed (or initially endorsed if there are two or more endorsements) for insurance, whichever rate is higher. The interest rate for debentures issued under these other provisions with respect to a loan or mortgage committed or endorsed during the 6-month period beginning 01/01/2019, is 3.375 percent. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-13/pdf/2019-09828.pdf. Federal Register, Vol. 84, No. 92, 05/13/2019, 20905-20906.

HUD Requests Comment on Information Collections.

  • HUD announced it seeks comment on the information collection titled Requisition for Disbursement of Sections 202 & 811 Capital Advance/Loan Funds. HUD also gave notice that it sent the collection to OMB for review. Comments are due 07/22/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-22/pdf/2019-10720.pdf. Federal Register, Vol. 84, No. 99, 05/22/2019, 23579-23580.
  • HUD announced it seeks comment on the information collection titled Single Family Insurance Premium Collection Subsystem—Upfront (Lender Assistance). HUD also gave notice that it sent the collection to OMB for review. Comments are due 07/22/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-22/pdf/2019-10721.pdf. Federal Register, Vol. 84, No. 99, 05/22/2019, 23580.
  • HUD announced it seeks comment on the information collection titled Comprehensive Transactional Forms Supporting FHA’s Section 242 Mortgage Insurance Program for Hospitals. HUD also gave notice that it sent the collection to OMB for review. Comments are due 07/23/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-24/pdf/2019-10932.pdf. Federal Register, Vol. 84, No. 101, 05/24/2019, 24167-24169.

FEMA Issues Final Flood Hazard Determinations.

The Federal Emergency Management Agency (FEMA) has issued a final notice which identifies communities in the states of Michigan, and Minnesota, where flood hazard determinations, which may include additions or modifications of Base Flood Elevations (BFEs), base flood depths, Special Flood Hazard Area (SFHA) boundaries or zone designations, or regulatory floodways on the Flood Insurance Rate Maps (FIRMs) and where applicable, in the supporting Flood Insurance Study (FIS) reports have been made final. The FIRM and FIS report are the basis of the floodplain management measures that a community is required either to adopt or to show evidence of having in effect in order to qualify or remain qualified for participation in FEMA’s National Flood Insurance Program (NFIP). The final notice is effective 08/15/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-06-05/pdf/2019-11669.pdf. Federal Register, Vol. 84, No. 108, 06/05/2019, 26135-26137.

FEMA Issues Final Rules on Suspensions of NFIP Community Eligibility.

FEMA issued a final rule which identifies communities in the states of Illinois, and Michigan, where the sale of flood insurance has been authorized under the National Flood Insurance Program (NFIP) that are scheduled for suspension on the effective dates listed within the final rule because of noncompliance with the floodplain management requirements of the program. If FEMA receives documentation that the community has adopted the required floodplain management measures prior to the effective suspension date given in the final rule, the suspension will not occur and a notice of this will be provided by publication in the Federal Register on a subsequent date. The effective date of each community’s scheduled suspension is the third date listed in the third column of the tables in the final rule. The final rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-16/pdf/2019-10190.pdf. Federal Register, Vol. 84, No. 95, 05/16/2019, 22049-22051.

FEMA Issues Final Notices of Changes in Flood Hazard Determinations.

FEMA issued new or modified Base (1% annual-chance) Flood Elevations (BFEs), base flood depths, Special Flood Hazard Area (SFHA) boundaries or zone designations, and/or regulatory floodways (hereinafter referred to as flood hazard determinations) as shown on the indicated Letter of Map Revision (LOMR) for communities in the states of Indiana, Ohio, and Wisconsin. Each LOMR revises the Flood Insurance Rate Maps (FIRMs), and in some cases the Flood Insurance Study (FIS) reports, currently in effect for the listed communities. The flood hazard determinations modified by each LOMR will be used to calculate flood insurance premium rates for new buildings and their contents. The effective date for each LOMR is indicated in the table in the final notice. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-20/pdf/2019-10391.pdf. Federal Register, Vol. 84, No. 97, 05/20/2019, 22877-22879.

FEMA Issues Proposed Flood Hazard Determinations.

FEMA has requested comments on proposed flood hazard determinations, which may include additions or modifications of any Base Flood Elevation (BFE), base flood depth, Special Flood Hazard Area (SFHA) boundary or zone designation, or regulatory floodway on the Flood Insurance Rate Maps (FIRMs), and where applicable, in the supporting Flood Insurance Study (FIS) reports for communities in the state of Wisconsin. The FIRM and FIS report are the basis of the floodplain management measures that the community is required either to adopt or to show evidence of having in effect in order to qualify or remain qualified for participation in the National Flood Insurance Program (NFIP). Comments are due 08/19/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-20/pdf/2019-10395.pdf. Federal Register, Vol. 84, No. 97, 05/20/2019, 22876-22877.

FinCEN Announces Innovation Hours Program.

The Financial Crimes Enforcement Network (FinCEN) is notifying the public of its Innovation Hours Program. Through the Program, FinCEN will provide dedicated time on a monthly basis to meet with financial institutions, regulatory and financial technology firms, and other stakeholders to enable them to share information with FinCEN about innovative approaches to evaluating, maintaining and reporting information under the Bank Secrecy Act in order to further strengthen the financial system against illicit financial activity. The program is effective 05/30/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-30/pdf/2019-11314.pdf. Federal Register, Vol. 84, No. 104, 05/30/2019, 25120-25122.

Treasury Finalizes Rule on Certain Transfers of Property to Regulated Investment Companies and Real Estate Investment Trusts.

The Department of the Treasury (Treasury) issued final regulations effecting the repeal of the General Utilities doctrine by the Tax Reform Act of 1986 and preventing abuse of the Protecting Americans from Tax Hikes Act of 2015 (PATH Act). The final regulations impose corporate-level tax on certain transactions in which property of a C-corporation becomes the property of a REIT. The final regulations affect RICs, REITs, C-corporations the property of which becomes the property of a RIC or a REIT, and their shareholders. The rule is effective 06/07/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-06-07/pdf/2019-11753.pdf. Federal Register, Vol. 84, No. 110, 06/07/2019, 26559-26565.

Treasury Proposes Amendments to Withholding of Tax and Information Reporting.

Treasury proposed regulations implementing certain sections of the Internal Revenue Code, including sections added to the Internal Revenue Code by the Tax Cuts and Jobs Act, that relate to the withholding of tax and information reporting with respect to certain dispositions of interests in partnerships engaged in the conduct of a trade or business within the United States. The proposed regulations affect certain foreign persons that recognize gain or loss from the sale or exchange of an interest in a partnership that is engaged in the conduct of a trade or business within the United States, and persons that acquire those interests. The proposed regulations also affect partnerships that, directly or indirectly, have foreign persons as partners. Comments are due 07/12/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-13/pdf/2019-09515.pdf. Federal Register, Vol. 84, No. 92, 05/13/2019, 21198-21225.

Treasury Proposes Withholding on Certain Distributions Under Section 3405(a) and (b).

Treasury issued a proposed regulation regarding withholding on certain periodic and nonperiodic distributions under section 3405, other than eligible rollover distributions. The regulation would affect payors and payees of these distributions. Comments are due 08/29/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-31/pdf/2019-11292.pdf. Federal Register, Vol. 84, No. 105, 05/31/2019, 25209-25212.

Treasury Requests Comment on Information Collections.

  • Treasury announced it seeks comment on the information collection titled Reverse Like-Kind Exchanges. Treasury also gave notice that it sent the collection to OMB for review. Comments are due 08/09/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-06-10/pdf/2019-12160.pdf. Federal Register, Vol. 84, No. 111, 06/10/2019, 26935.
  • Treasury announced it seeks comment on the information collection titled OFAC Application for the Release of Blocked Funds. Treasury also gave notice that it sent the collection to OMB for review. Comments are due 07/10/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-06-10/pdf/2019-12139.pdf. Federal Register, Vol. 84, No. 111, 06/10/2019, 26935-26936.

FHFA Requests Comment on Information Collection.

The Federal Housing Finance Agency (FHFA) announced it seeks comment on the information collection titled American Survey of Mortgage Borrowers. FHFA also gave notice that it sent the collection to OMB for review. Comments are due 07/29/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-29/pdf/2019-11182.pdf. Federal Register, Vol. 84, No. 103, 05/29/2019, 24783-24796.

SBA Proposes Amendments to Women-Owned Small Business and Economically Disadvantaged Women-Owned Small Business Certification.

The Small Business Administration (SBA) is proposing to amend its regulations to implement a statutory requirement to certify Women-Owned Small Business Concerns (WOSB) and Economically Disadvantaged Women-Owned Small Business Concerns (EDWOSB) participating in the Women-Owned Small Business Contract Program. Comments are due 07/15/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-14/pdf/2019-09684.pdf. Federal Register, Vol. 84, No. 93, 05/14/2019, 21256-21267.

SBA Requests Comment on Information Collections.

SBA announced it seeks comment on the information collection titled Small Business Investment Companies. SBA also gave notice that it sent the collection to OMB for review. Comments are due 06/17/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-16/pdf/2019-10142.pdf. Federal Register, Vol. 84, No. 95, 05/16/2019, 22221-22222.

FCA Issued Statement on Regulatory Burden.

The Farm Credit Administration (FCA) issued a statement discussing comments raised about FCA regulations and FCA activities in response to a 05/18/2017 Federal Register invitation for public comment on the regulatory burden imposed on the Farm Credit System. Many of the comments concern changes that FCA cannot implement because they are inconsistent with the Farm Credit Act of 1971, as amended (Act), safety and soundness, and/or other FCA guidance or position. Some comments raise issues that are the subject of existing regulatory projects scheduled for consideration by FCA as set forth in the 2019 Regulatory Projects Plan, which is available on the FCA website, and those issues will be addressed in the planned regulatory projects. In other cases, commenters identify issues that need further evaluation before FCA can consider whether changes are appropriate. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-15/pdf/2019-09960.pdf. Federal Register, Vol. 84, No. 94, 05/15/2019, 21693-21698.

FTC Rescinds Model Forms and Disclosures.

The Federal Trade Commission (FTC) is rescinding several Model Forms and Disclosures promulgated pursuant to the Fair Credit Reporting Act (FCRA) that it has determined are no longer necessary. The Dodd-Frank Act transferred rulemaking authority associated with these forms and disclosures to the Bureau of Consumer Financial Protection (CFPB). Given CFPB’s 2018 updates to its model forms and disclosures, FTC has determined that rescinding several of its model forms and disclosures would reduce confusion. FTC is also making conforming amendments to address references to the updated model forms and disclosures in related rules. The rescission is effective 05/22/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-22/pdf/2019-10110.pdf. Federal Register, Vol. 84, No. 99, 05/22/2019, 23471-23486.

FTC Extends Comment Deadline for Proposed Standards for Safeguarding Customer Information.

FTC is extending the deadline for filing public comments on its recent Notice of Proposed Rulemaking on the Standards for Safeguarding Customer Information. The new comment due date is 08/02/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-24/pdf/2019-10910.pdf. Federal Register, Vol. 84, No. 101, 05/24/2019, 24049-24050.

NCUA Proposes Amendments to Public Unit and Nonmember Shares.

The National Credit Union Administration (NCUA) is proposing to amend NCUA’s public unit and nonmember share rule to allow Federal credit unions (FCU) to receive public unit and nonmember shares up to 50 percent of the credit union’s paid-in and unimpaired capital and surplus less any public unit and nonmember shares. Comments are due 07/29/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-30/pdf/2019-11296.pdf. Federal Register, Vol. 84, No. 104, 05/30/2019, 25018-25022.

NCUA Requests Comment on Information Collection.

The National Credit Union Administration (NCUA) announced it seeks comment on the information collection titled Small Business Investment Companies. NCUA also gave notice that it sent the collection to OMB for review. Comments are due 06/20/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-21/pdf/2019-10540.pdf. Federal Register, Vol. 84, No. 98, 05/21/2019, 23070-23071.

VA Requests Comment on Information Collection.

  • The Department of Veterans Affairs (VA) announced it seeks comment on the information collection titled Claim for Repurchase of Loan, VA Form 26–8084. VA also gave notice that it sent the collection to OMB for review. Comments are due 06/20/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-21/pdf/2019-10534.pdf. Federal Register, Vol. 84, No. 98, 05/21/2019, 23166-23167.
  • VA announced it seeks comment on the information collection titled Loan Analysis, VA form 26– 6393. VA also gave notice that it sent the collection to OMB for review. Comments are due 06/24/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-24/pdf/2019-10942.pdf. Federal Register, Vol. 84, No. 101, 05/24/2019, 24202.

DOL Extends Comment Period for Joint Employer Status Under the Fair Labor Standards Act.

The Department of Labor (DOL) extends the period for submitting written comments on the Notice of Proposed Rulemaking (NPRM) entitled “Joint Employer Status Under the Fair Labor Standards Act.” The comment period now ends on 06/25/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-14/pdf/2019-09841.pdf. Federal Register, Vol. 84, No. 93, 05/14/2019, 21301-21302.

DOL Extends Comment Period for Regular Rate Under the Fair Labor Standards Act.

DOL extends the period for submitting written comments on the Notice of Proposed Rulemaking (NPRM) entitled “Regular Rate Under the Fair Labor Standards Act.” The comment period now ends on 06/12/2019. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-05-14/pdf/2019-09842.pdf. Federal Register, Vol. 84, No. 93, 05/14/2019, 21300-21301.

SSA Announces Initial Enrollment Period for Electronic Consent Based Social Security Number Verification Service.

The Social Security Administration (SSA) is announcing the initial enrollment period for a new electronic Consent Based Social Security Number (SSN) Verification (eCBSV) service. SSA will roll out the service to a limited number of users in June 2020, and plans on expanding the number of users within six months of the initial rollout. All interested permitted entities must apply during this initial enrollment period to be eligible to use the new eCBSV service during either the initial rollout or subsequent planned expansion. Permitted entities that do not apply during the initial enrollment period must wait until the next designated period after the planned expansion to apply for enrollment. The initial enrollment period for permitted entities will begin on 07/17/2019, and remain open until the period closes on 07/31/2019. In accord with statutory requirements, permitted entities will be required to provide payment to build the new eCBSV system. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2019-06-07/pdf/2019-11995.pdf. Federal Register, Vol. 84, No. 110, 06/07/2019, 26712-26713.

By, Ally Bates

Got questions on banking customers engaged in hemp-related activities in Wisconsin? 

FIPCO has developed a form that helps your bank ask the right questions and obtain the documentation needed to determine if your customer is complying with Wisconsin law. This form specifically provides a list of questions staff should be asking as well as a Certification that may provide your financial institution with additional comfort in banking these customers.

This questionnaire will benefit: 
Loan Officers, BSA officers, Compliance Officers, Corporate decision-makers

Annual Cost (fillable PDF)

  • WBA Member: $195 
  • Non-WBA-Member: $235
  • FIPCO Compliance Concierge Software User: complimentary (accessed through Blank Forms at www.fipco.com). This complimentary form will be included directly in the software soon.

NOTE: The annual cost of the form includes free updates and revisions, should they be made to the form.

What does the Hemp Questionnaire and Certification provide to my bank? 

  • A document solution for banking participants in the hemp industry. 
  • A list of questions to ask the Applicant in order to make decisions about the risk level in banking the Applicant 
  • Documentation the bank should consider obtaining when banking participants in the hemp industry 
  • Additional comfort in banking these parties

How will it directly help my bank? 
Provides the framework of questions to ask and documentation available to make determinations about whether the Applicant should be banked, consistent with your financial institution's policies and procedures.

Why should my bank purchase the Hemp Questionnaire and Certification?

  • This document distills Wisconsin law into a pragmatic document solution that allows you to ask the right questions and obtain the documentation necessary to determine whether the Applicant is complying with Wisconsin law. 
  • It asks questions that are relevant in determining whether your financial institution and/or the Applicant are in compliance with all applicable laws and regulations. 
  • It's flexible and can be customized to be consistent with your policies and procedures. Contact fipcoforms@fipco.com for more information.

Buy now! Contact fipcoforms@fipco.com.

By, Amber Seitz

 Film Industry: "We have the best oligopoly in the U.S." 
Communications and Media Industry: "We have the best oligopoly in the U.S." 
Core Banking Service Providers: "Hold my beer." 


Mike Semmann profileA report that ran at the end of last year details two of the most well-known oligopolies in the United States as the film (six companies which earned $5.2 billion in 2016) and wireless communications industries (four companies that account for 98% of wireless revenues). So, if all U.S. industries were in a business history class together, would the banking core service providers be over-achieving students or would they be the teaching assistants?

Regardless, this current oligopolistic tale should remind bankers of a history lesson: The Battle of New Orleans. On Dec. 24, 1814, Great Britain and the United States signed a treaty that effectively ended the War of 1812. News traveled slow back in the day, and on Jan. 8, 1815, the two sides met in what is remembered as one of the conflict's biggest and most decisive engagements. While the battle may have provided clarity, it was fought after the war was over and caused a great deal of bloodshed.  

Fast forward to October 2013, when the American Banker asked Can Big Four Core Banking Vendors Oligopoly Be Broken?. The answer in early 2018 seemed not be, "not yet." However, in late 2018 and early 2019, national banking trade groups began a new and potentially more robust salvo in the core services fray. This time, major national media seem to be willing to listen. (Maybe it's the consolidation of the financial services industry. Maybe it's a high-profile stadium.)  

In October 2018, the American Bankers Association (ABA) formed a Core Platform Committee, which is composed of bankers charged with identifying "concrete ways to address the challenges and limitations banks have with current core providers." Then, in January of this year, the ABA announced a direct investment in Finxact, an emerging technology company that offers an innovative, open core banking platform for financial institutions.  

The Wall Street Journal took note in April and reported on this new round of Rochambeau for greater digital equity. The WSJ article examined the challenges that many community banks face when working with their core processors to implement new technologies and remain competitive with larger institutions. It also highlighted the ABA's efforts to help banks innovate more quickly. 

Which brings the banking industry to this particular moment in time. Given the rate of M&A activity, especially in Wisconsin, is the banking industry at the beginning or the end of this chapter of the core processor business cycle, particularly in light of the current digital transformation occurring nationwide? Wisconsin's banking industry must decide if this battle is one that must be fought at this moment in time, or if there is a larger threat on the horizon. 

Basic economic theory tells bankers that oligopolies (even ones created by the banking industry) lead to decision-making bias, poor service, irrational behavior through market manipulation, and inefficient marketplaces. Just to taunt, they create the appearance of choice without giving one to the consumer (banks).  

So, maybe this is a necessary struggle. A preview of the first battleground in Wisconsin: data accessibility and readability.

Semmann is WBA executive vice president – chief operations officer.

By, Amber Seitz

Nick Brandoch profile
Kristen Talbott profileAll businesses exist for one reason: to serve their customers. Today, we are blessed to be able to communicate with and serve those valuable customers in more ways than ever. The challenge for brands is to be consistent with their messaging and experience across those channels, whether they be in person or through a digital environment. Achieving that goal requires a close connection and ongoing collaboration between retail and marketing, the two main customer touchpoints within our banks. 

We've been working together for the past year and a half, and these are the best practices we've used for successful collaboration. 

  1. Set the vision. Together. People have a more vested interest in goal achievement when they play a role in setting goals. We allocated time together to plan for 2019 as a team. Our initiatives are not retail or marketing initiatives; they are bank-wide goals that are supported by multiple departments. 
  2. Get friendly. Collaboration can't stop after goal setting. Ongoing communication helps us address problems, make continual improvements, and keep goals top of mind. Nicholas joins the regular meeting of our retail leadership to provide marketing updates, take feedback, and ensure lines of communication always remain open. With more time spent in the branch network, Kristen and her team help audit branch merchandising and communicate opportunities to marketing.
  3. United we stand. Once you figure out what you want to accomplish, together, you have additional resources when presenting opportunities to bank leadership. When you've found consensus between retail and marketing, you'll find it substantially easier to find commitment from the top to execute your shared vision. 
  4. Make the tent bigger. When the retail team was facing staffing shortages, marketing developed hiring campaigns to help drive qualified applicants. This led to a new hire starting within the first two weeks. When marketing needed employees to support events, retail recruited front-line employees to be offsite brand ambassadors. They were able to share bank knowledge with potential customers, and now share greater marketing knowledge with fellow employees. Solutions exist beyond department boundaries. Be sure to push the boundaries and ask for help. 
  5. That computer in your pocket makes calls. Really. Don't forget how critical your Call Center is to a great customer experience. Trust can be lost when call center employees are unfamiliar with initiatives or key advertising. Share those campaigns ahead of time so the customer has an omni-channel experience. 
  6. Maximize your sponsorships. In a community bank, sponsorship opportunities arise from the extensive network that our bankers and lenders keep. To maximize these investments, teamwork is required. Retail can help activate marketing sponsorships within the branch, encouraging customer engagement as well as reinforcing our community niche. Conversely, marketing can use its expertise to negotiate and leverage partnerships that originate from the retail team for the greatest impact. 

Harmony can be elusive. Building trust is hard. It takes a concerted effort to keep retail and marketing rowing their oars in the same direction. Occasionally, your boat will take a circuitous route. We believe these best practices can help you arrive at your final destination. 

Talbott is chief retail banking officer for Tri City National Bank and serves on the WBA Marketing Committee. Bandoch is vice president of marketing for Tri City National Bank.

By, Amber Seitz

No matter what role traditional banks choose to play in the future, customer service is the key to thriving in a landscape transformed by tech

Amber Seitz profileBankers can't open a trade publication today without reading headlines about all of the changes coming to the industry and the challenges they present to traditional retail banks. In the drama of the financial services industry, banks have been cast as victims, or worse, minor side characters doomed to be killed off in the third act. However—despite those changes and challenges—traditional, Main Street banks are well-positioned to define their own role in the future of financial services, no matter what that landscape looks like. In fact, the greatest challenge facing the banking industry is also its greatest advantage over disruptors: bank customers.

Setting the Stage: Challenges Ahead

Isolated core systems, deposit displacement, limited IT resources… The list of challenges banks face today is long, but the most critical is the fact that customer expectations are now being set externally, according to Rob Morgan, vice president of emerging technologies at the American Bankers Association. "It used to be your competitor was the bank down the street," he explained. "Today, your competitor is your customers' last best experience, whether it's with a bank, with you, or with Google or Amazon." As small fintech startups have grown into market share-leading behemoths, customers' standards are shifting faster than ever. "We need to realize that the 'upstart' fintech companies are 'mainstream' fintech companies, and they're changing the way our customers expect to interact with financial institutions," said David DeFazio, partner at StrategyCorps. For example, Credit Karma has over 80 million users on its app and has referred nearly $40 billion in loans to their partner institutions (users view mortgage and credit card offers). 

In addition to elevated expectations for their digital experience, bank customers today also have a much stronger preference for self-service than in the past, though most still expect hands-on treatment in certain situations. "Anyone at the younger end of the millennial generation on down has a different mindset," said Tina Giorgio, president and CEO of ICBA Bancard. "They want both consultative and on-demand service." Traditional banks must ensure that their customers receive top-notch service no matter which channel they use. "Digital gives the customer 24-hour access to the bank, so we want to foster that, but we also need to make sure their experience is the same as if they were here in person," explained Dave Werner, president and CEO, Park Bank, Milwaukee. 

Another common challenge for banks is directly related to these transforming customer expectations: how to deliver a cutting-edge digital experience via their current core system's infrastructure. "The biggest inhibitors for banks right now are their core service providers who are not letting them innovate quickly and freely," said Girish Ramachandra, senior manager leading fintech and blockchain initiatives at Wipfli, LLP. He explained that one of the most significant changes in banking today is the push for open banking, where consumers control their own data. "Having a multi-year contract with a core service provider is the biggest inhibitor to open banking," since it prevents banks from collaborating with various fintech companies, he said.

A final challenge connected to customer expectations is deposit displacement—the growing phenomenon of consumers storing their funds in technology and retail companies' apps rather than in a deposit account at a financial institution. For example, Starbucks' rewards program as 16.8 million active users who store over $1.5 billion on their Starbucks cards and app, and those funds account for nearly 40% of their purchases at U.S. locations. The benefit to retailers is this strategy dramatically reduces their transaction fees because customers load $20-$150 on the app or card rather than purchasing single coffees for $6.75 a piece. DeFazio estimates Starbucks has reduced their transaction processing fees by $20 million per quarter. With deposits at a premium in the financial services industry, the growing percentage of funds that could be deposits kept in a checking account but are instead held on retail cards and apps is a concern. "Checking accounts are the anchor product. Just offering a free checking account leaves you vulnerable to losing business to non-bank competitors with more attractive offers," DeFazio warned. "It's all based on convenience, value, and rewards."

The Cast of Characters: Transformative Technologies 

As they grapple with the challenges presented by changing customer expectations, banks also must adapt to and utilize the technologies that contributed to that transformation and continue to drive change. Of all the technology looming on the horizon, artificial intelligence (AI) gets perhaps the most attention, and for good reason. "What I'm seeing in the market is the biggest technology impact is coming from artificial intelligence," said Ramachandra. "The scope of AI is broad and it's already happening, especially in lending, wealth management, and customer support." According to a survey published by the Financial Stability Board in 2017, AI and machine learning firms managed assets of over $10 billion, and that number is projected to grow. AI's tremendous potential impact on the banking industry has drawn attention and investment from both the technology and banking industries. "As our chairman and CEO, Jamie Dimon, highlighted in his shareholder letter recently, we're all in on artificial intelligence, machine learning, and 5G and see the value that they'll provide for banking," said Al Araque, executive director – market director banking, JPMorgan Chase, New Berlin. Araque says banks will be able to utilize AI to help identify trends in customer feedback, help mitigate fraud, and work to personalize the customer experience. 

On another front, Giorgio says faster payments will also have a big impact in the future, whether they are near-time or instant. "We're all being measured to a different standard as banks," she explained. "We're not just measured against other banks, but against every other company online. The ability to open an account quickly and move money quickly will be critical in the future." As with AI, technological developments in payments could also bring enhanced security for banks and their customers. "I think in the next two or three years we'll see a significant shift to tokens in the ecommerce world, and we'll need to be prepared for that," said Giorgio. She also cited contactless payments as an area of significant growth and change. "Over 70% of existing POS locations in the U.S. accept a contactless payment, and it's being adopted by merchants at a rate of 1-2% per month," she explained. "That's huge." 

Though it's been making headlines for a few years, blockchain technology hasn't caught on in the financial services industry… yet. "Blockchain is slowly making its way into bigger companies. They're experimenting with how it can be used for settlements," Ramachandra explained. "Once it starts working, they'll scale it up and expand into many areas." Araque says JPMorgan Chase believes in the potential of blockchain technology and cryptocurrencies, provided they are properly regulated. "As a globally regulated bank, we believe we have a unique opportunity to develop the capability in a responsible way with the oversight of our regulators," he explained. "Ultimately, we believe that JPM Coin can yield significant benefits for blockchain applications by reducing clients' counterparty and settlement risk, decreasing capital requirements, and enabling instant value transfer." 

A dark horse to watch in this space is the Internet of Things, especially when paired with wearable devices. "We've just started to scratch the surface with IoT and wearables," said Giorgio. "The Internet of Things as we know it will really change the way we do things." For example, high-tech refrigerators that track your usage and can reorder items when you run low need to be hooked to some form of payment system, whether it's a technology app or a checking account. Combined with wearable technology, bank customers may one day transfer funds with a tap on their smartwatch so their car can pay for gas as they fill up on the way to work. These are all opportunities for banks to be even more present in their customers' lives.

Two Possible Roles in Banking: Distributor or Conduit

The stage is set and the characters assembled. What role will traditional banks play as the drama of financial services unfolds? There are two likely options: "In the very long-term, just like what happened in retail where small retailers have now started selling on Amazon, I think the banking industry is going to be two different types of industries: banking and distribution of banking," said Ramachandra. In the distribution model, traditional depository banks will still be the core banking providers (i.e. deposits and loans), but they'll sell those products on platforms provided by technology companies (the distributors). One example is Apple's recently announced AppleCard—the first step in the company's stated goal of transitioning from a "consumer product company" to a "consumer services company"—which is issued in partnership with Mastercard and Goldman Sachs. "What they're doing is selling financial services through your mobile phone," Ramachandra explained. "All the credit card data is on the phone, not visible on the card." The physical card has no number, CVV security code, signature, or expiration date, for example.

In the banking model, banks will continue selling their products and services to customers directly and rely on strong customer relationships to compete. One effective way to deepen those relationships in a technology-reliant world will be for banks refer customers to non-bank solutions when appropriate. "We need to be smart about what products and services we aren't offering but might be beneficial to our customers that we can recommend," said Werner. "It's becoming a conduit to other products and services and thereby enhancing our relationship with our customers as knowledge-brokers." The benefit of the conduit model for banks is that it fosters and deepens existing customer relationships. "You give your customers access to the entire ecosystem of products that are out there," Morgan explained.

Banks will likely choose between either the traditional banking model or the distribution model, or some combination thereof. Either way, the business of banking—accepting deposits and making loans—will remain at the center of the industry. "It's the core banking practices that we've always deployed that will drive our success in the future," said Werner. "Our ability to determine levels of risk and make educated, risk-based decisions on how we'll lend money."

Curtains Up: Time to Act

So, what should banks do today to prepare for the financial services landscape of tomorrow?

What they've always done: focus on providing their customers with the best possible service and value. "As we've seen in other areas, technology can shift the ground, but only when it changes the primary customer relationship," Morgan explained. If banks make their customers the bedrock of their strategy, it will equip them to thrive amid all the coming changes. "There are a lot of things happening that will come our way fairly quickly, and we need to be prepared to work within those new solutions," Giorgio advised. "It's all about putting the customer first and approaching this new world with that in mind." At Chase, Araque says a strong focus on listening and understanding customers' needs drives change and pushes the bank to evolve as they strive to remain competitive. "It forces us to keep an open mind and substantiates the value of always keeping the customer in the center of everything that we do," Araque explained. 

Traditional banks have operated legally in Wisconsin since 1853, and that long history has led to tremendous trust from consumers. "Banks still command the highest level of trust when it comes to the security of people's money compared to any other industry," said Werner. "As long as we maintain that trust, and it's incumbent upon us to do so, it will provide us a competitive advantage, especially when we're in competition with unregulated or less-regulated entities." Morgan says community banks are well-positioned going into the future. "They've always been relationship-based businesses," he explained. "The key is meeting customers digitally and providing them the same level of service they expect from other channels."

Here are five tactics recommended by the experts interviewed for this article that banks should consider utilizing in their efforts to serve their customers: 

1. Integrate technology strategy-not just maintenance-into the bank's strategic plan.
"In their strategy discussions, community banks must include technology strategy," said Ramachandra. "A technology maintenance plan must change into a technology impact plan." Werner advises banks to consider reinvesting the personnel cost-savings from efficiencies gained from technology back into technology. "Reinvesting those expenses into the technology side allows us to deliver at a very high level, which requires constant reinvestment. You have to constantly consider that as part of your capital planning," he said. "It will become a bigger and bigger part of everybody's budget."

2. Offer in-demand products.
"Right now, what I'm telling community banks is that they have to hop on the Zelle bandwagon," said DeFazio. "Zelle and Venmo are the new standards for P2P interactions. It's not an experiment anymore. They're the way millennials expect P2P services to work." Specifically, those apps have eliminated the need for consumers to find workarounds or enter lots of sensitive information—such as account numbers—in order to transfer funds from an account at one institution to an account at another institution. "It's going to be had to win the customers of the future if you don't have those standards in place," said DeFazio. 

3. Renegotiate core contracts.
"What banks should be doing is getting out of their existing contracts with core service providers," said Ramachandra. "Renegotiate those core service provider contracts so you have the ability to work with a number of different fintech companies."

4. Continue to speak up and be visible in your community.
"Continue to speak up as an industry," Werner urged. "Bankers historically have been humble people, not wanting to shine a spotlight on all the good they've done in their communities. We need to be willing to step up into that spotlight and show what we've done so people are aware of the importance of banks to their communities and their economy."

5. Focus on small changes. Innovation does not need to be dramatic.
"The biggest mindset shift for me has been around the idea that innovation needs to be dramatic," said Morgan. "I don't think that's the case anymore. More often in mature industries like banking you see innovation that compliments the core product, rather than something that radically shifts the core product. It's about understanding customers' needs and adding technology that facilitates their access, not changing your business model."

Wipfli, LLP is a WBA Silver Associate Member.

By, Amber Seitz

The Joint Committee on Finance continues to make its way through the budget process. This week, JFC is meeting twice to approve various sections of the 2019-2021 State Budget.

On Tuesday, the big discussion was over the Department of Health Services – specifically Medicaid funding. Republicans on the committee approved a plan to spend an additional $588.2 million in general purpose revenue into the Medicaid program, pushing up reimbursement rates for hospitals, nursing homes, and personal care workers.

The investment of state tax dollars would mean an additional $858.4 million in federal funds that would help cover costs of the joint state-federal Medicaid program.

But Dems slammed the GOP proposal as inadequate because it didn't embrace Governor Tony Ever's call to expand Medicaid under the Affordable Care Act. They pointed out that approach would have saved the state $324 million in GPR while resulting in an additional $1.6 billion investment in health programs.

On Thursday, the committee will consider transportation funding. A group of Senate Republicans on Wednesday announced plans to increase local road funding by more than $130 million. The 10 Senate Republicans at the news conference included all six caucus members on the Joint Finance Committee. The plan includes giving each county $1 million and providing towns with $1,000 per mile of road in their jurisdictions.

The package would also be one-time money, taking advantage of new revenue projections the Legislative Fiscal Bureau released last month. The agency now projects an additional $753 million in revenue through mid-2021 compared to previous estimates. Still, it noted much of that was one-time money as taxpayers take advantage of the 2017 rewrite of the federal tax code.

In non-budget news, the Wisconsin State Senate was on the floor on Wednesday debating a series of bills, most notably four bills that dealt with abortion. Those included the banning of abortion based on the sex of the baby, requiring doctors to care for children born alive following abortion, and certain certifications of abortion providers. Evers has already announced he will veto all those bills. 

Next week's schedule has not been announced, but we expect the Joint Finance Committee to meet both Tuesday and Thursday again.

By, Jon Turke

The Wisconsin Coalition on Student Debt held the first-ever Money Smart Essay Contest for high school seniors in Southwest Wisconsin during Money Smart Week, March 30 – April 6, 2019. Students from Dane, Grant, Green, Iowa, Jefferson, Lafayette, and Rock County had the opportunity to write an essay about how they plan to finance their college education for a chance to win one of three $1,000 Edvest gift cards.

Gift card sponsors included:

Oregon Community Bank

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Park Bank, Madison

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Settlers bank, Windsor

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And other financial supporters. Thank you!


Members of the Coalition reviewed and scored 43 essay submissions based on criteria including research, identifying funding sources for college, and explaining how school choice will further the student’s career.

Throughout the month of May, Coalition members traveled the southwest corner of the state awarding the scholarships and presenting the Edvest gift cards. Congratulations to the following winners:

  • Kianna Jenswold – Jefferson High School
  • Alyssa Kuhn – Waunankee High School
  • Hannah Wilson – Beloit Memorial High School

“We are proud to support these deserving students as they continue their education,” said Wisconsin Bankers Foundation Executive Director Mike Semmann. “Wisconsin's banks have always been strong supporters of their communities, and this is just one more example of that long-standing tradition.”

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Pictured above (left to right): Scholarship Winner Kianna Jenswold; Cheryl Rapp, DFI College Affordability Specialist; Amber Seitz, Wisconsin Bankers Foundation Financial Literacy Manager; Casey Koenig, Oregon Community Bank Vice President – Business Banking; and Kristel Renn, Summit Credit Union.

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Pictured above (left to right): Brian Kersten, Waunakee Principal; Cheryl Rapp, DFI College Affordability Specialist; Dave Mancl, DFI Director – Office of Financial Literacy; Scholarship Winner Alyssa Kuhn; Kathy Blumenfeld, DFI Secretary; Steven Erickson, Waunakee Community Bank; Amy Crowe, Summit Credit Union.

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Pictured above (left to right): David Mancl, DFI Director Office Financial Literacy; Stephanie Johnson, Oregon Community Bank; Kathy Blumenfeld, DFI Secretary; Scholarship Winner Hanna Wilson; Erin Wolf, Guidance Counselor; Mr. Anthony Bosco, Interim Superintendent; Emily Pelz, Interim Principal; Cheryl Rapp, DFI College Affordability Specialist


Organizations participating in the Wisconsin Coalition on Student Debt include: Ascendium Education (f/n/a Great Lakes Higher Education); Boys & Girls Club; Fair Opportunity Project; GreenPath Financial Wellness; Herzing University; Madison Metropolitan School District; Medical College of Wisconsin; Navient; Summit Credit Union; University of Wisconsin; Urban Economic Development Association of Wisconsin; UW Credit Union; WEAC; Western Technical College; Wisconsin Association of Independent Colleges and Universities; Wisconsin Bankers Foundation; Wisconsin Department of Financial Institutions; and Wisconsin Manufacturers and Commerce.

For more information about Money Smart Week, visit www.moneysmartweek.org. To search a library of financial education resources for consumers and educators, visit MyMazuma.com.

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The Wisconsin Bankers Foundation (IRS Public Charity Employer Identification Number 46-3791061) is a Wisconsin non-stock corporation organized for charitable and education purposes dedicated to promoting financial literacy and financial responsibility to the public and to broaden consumer empowerment in the financial services industry primarily through research and education.

By, Amber Seitz