By: Rose Oswald Poels
As many WBA members know, our Association has been fighting off proposed interchange regulation for over a year. At the state level, WBA and banking advocates from throughout Wisconsin successfully halted AB 587/SB 572, which called for the prohibition of interchange fees on the tax portion of a transaction. While grassroots involvement by Wisconsin bankers has helped us clear one hurdle, it is clear that retailers and legislators alike are prioritizing moving this issue forward at both the state and federal levels.
In late July, Sen. Dick Durbin (D-IL) and Sen. Roger Marshall (R-KS) introduced the bipartisan Credit Card Competition Act of 2022 (S.4674). The proposed legislation — which is largely opposed by members of the American Bankers Association (ABA), Independent Community Bankers Association (ICBA), and banking trade associations from across the U.S. including WBA — would require banks exceeding $100B to offer customers at least two networks to process credit cards — one of which is required to be a provider other than Visa or Mastercard. According to Durbin, this proposed legislation “injects competition into the Visa-Mastercard duopoly.”
Last week, the House companion to the Credit Card Competition Act of 2022 (H.R.8874) was introduced by Rep. Peter Welch (D-VT) and Rep. Lance Gooden (R-TX). Again, legislators claim that this proposal will cut costs for businesses and families.
Although Wisconsin’s community banks are not the current target of this proposed legislation, the Credit Card Competition Act of 2022, active now in both the U.S. Senate and House, will require a complete and costly overhaul of the U.S. payment system that every consumer and institution will feel the impact of.
In addition, credit card merchants would be given the ability to force transactions to cheap, less secure networks; more Americans would lose access to valued cash-back and reward programs that drive spending or credit altogether; and with an increase in regulation, the independence and competitiveness of community banks is put at risk.
For the sake of our current financial system, the security and choice of all consumers, and the continued prosperity of community banks across the state and country, I encourage you to join WBA in opposing these two proposed legislative actions.
Grassroots advocacy is a critical component of WBA’s advocacy efforts as we need banker involvement to help ensure the industry’s voice is heard. Please make time to call your House Representative or email them a message — let them know that you stand with the best interest of our communities and customers in mind. You can easily take action now on ICBA’s website and ABA’s website. Your engagement has time and time again proven vital and highly effective in fending off threats to our industry. Thank you in advance for your help informing our congressional delegation of these concerns.
If you have any questions regarding how these proposals will impact Wisconsin community banks or wish to designate an Advocacy Officer to assist the Association in coordinating regulatory, legislative, and community advocacy efforts, please contact WBA Vice President – Government Relations Lorenzo Cruz or me.
The following is a brief interview between WBA President and CEO Rose Oswald Poels and Community First Bank President/CEO Dan Klahn.
Rose: How did you first get into the banking industry?
Dan: After graduating from college with a degree in economics, I began working in a sales and lending position with a finance company. I discovered I really enjoyed the customer contact and finding ways to help meet customer needs. While working there, I was able to see the positive effect that community banks have on their customers and communities. This led me to join a small community bank in southwest Wisconsin. A few years later, I joined Community First Bank in Boscobel, where I have been for the last 33 years of my career. Working in a smaller community bank has given me the opportunity to learn and grow as one must wear many hats and do a little bit of everything. This eventually led to my current role as president and CEO.
What is your favorite aspect of your role at your bank?
My favorite aspect of my role at the bank is the ability to positively affect people’s lives. I have been fortunate to be able to develop relationships with individuals and businesses that have lasted 30+ years. This includes being there for them through the good times and bad. Some of these long-term relationships began as start-up businesses that have grown and prospered and are now major employers in the communities we serve.
Another favorite part of my job has been mentoring employees and being able to watch them learn and grow within our organization. Community First Bank has had a number of employees who started with us in high school or college and have now grown into leadership positions within the bank.
What do you wish the general public understood about the banking industry?
I wish the general public better understood the commitment and contributions that community banks and their employees make to their customers and communities every day. We truly have a vested interest in helping our communities thrive as our employees and their families live, work, and go to school in the communities they serve. I believe we’ve “gained some ground” through the pandemic as the extraordinary efforts put out by the banking industry to help our customers was more visible and recognized. However, we as an industry need to continue to educate the general public about the positive effects we have on the economy and the communities we serve.
Where do you believe the industry’s greatest challenges are in the next three to five years?
I think one of community banking’s greatest challenges over the next 3 to 5 years will be related to keeping up with rapidly evolving cybersecurity risks, technology, and complying with the ever increasing regulations. Our industry will need to continue to focus on ways to manage these challenges as we go into the future. In Wisconsin, we are fortunate to have a very strong trade group in the Wisconsin Bankers Association (WBA) to lead advocacy efforts and help us manage some of the challenges we face.
Please share one of your more rewarding or memorable experiences with us.
I think the most rewarding experiences for me in my career revolve around participating and watching our employees step up to the plate when our communities needed us most. A couple of examples of this include watching our employees fill and deliver sandbags to businesses during the 2008 and 2018 floods in Reedsburg and assisting in cleanup efforts for the tornado that hit Boscobel in 2021. It was also extremely rewarding to serve witness to the Community First Bank team working tirelessly to help our customers by quickly processing hundreds of PPP loans during the pandemic in 2020 and 2021.
Banks need be aware of a recent Freedom of Information Act (FOIA) request of the Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) for all Type 2 Consolidated Employer Information Reports, Standard Form 100 (EEO-1), filed by federal contractors from 2016-2020. OFCCP announced the request in the August 19, 2022, edition of the Federal Register. The FOIA request was made by Will Evans of the Center for Investigative Reporting (CIR). It is expected Evans seeks the information for further reporting about the racial, ethnic, and gender composition of federal contractors’ employees.
As stated in the Federal Register notice, OFCCP has reason to believe that the information requested may be protected from disclosure under FOIA Exemption 4, which protects disclosure of confidential commercial information, but has not yet determined whether the requested information is protected from disclosure under that exemption. OFCCP has requested that entities that filed Type 2 Consolidated EEO-1 Reports as federal contractors at any time from 2016-2020, that object to the disclosure of the information, to submit those objections to OFCCP within 30 days of the date of the notice.
Objections must be filed with OFCCP by September 19, 2022.
For banks that consider themselves to be federal contractors, WBA urges the bank to file objections to the disclosure of its EEO-1 Report data by the filing deadline. OFCCP has stated that if it does not receive a written objection by September 19, it will assume that the federal contractor has no objection to the disclosure and will begin the process of sending specific EE0-1 Report data to the FOIA requester.
Background
Will Evans of CIR submitted a FOIA request for “[a] spreadsheet of all consolidated (Type 2) EEO-1 reports for all federal contractors for 2016.” CIR subsequently amended the request multiple times, most recently on June 2, 2022, to include Type 2 EEO-1 reports for all federal contractors, including first-tier subcontractors, from 2016-2020. The Type 2 EEO-1 report is one of several different types of reports that multi-establishment employers must file annually, which consists of a consolidated report of demographic data for all employees at headquarters as well as all establishments, categorized by race/ethnicity, sex, and job category.
Title VII of the Civil Rights Act provides statutory authority for the EEO-1 Reports. The Equal Employment Opportunity Commission (EEOC) enforces the employment nondiscrimination law. See 42 U.S.C. 2000e-8(c). The EEOC’s regulations require employers with 100 or more employees to file the EEO-1 Report with the EEOC. See 29 CFR 1602.7. In addition, OFCCP’s regulations require federal contractors and first-tier subcontractors that are covered by Executive Order 11246 and that have 50 or more employees to file the EEO-1 Report.
Banks as Federal Contractor
Whether a bank is a federal contractor for purposes of having to file an EEO-1 Report is a determination banks have previously made with instruction from bank counsel. Therefore, each bank should already have determined whether it must file an EEO-1 Report, including whether it had filed such report in 2016-2020.
Regarding OFCCP’s interpretation of federal contractor, there are a couple of items to consider. First, OFCCP has concluded through an “FAQ” posted on its website that because deposit insurance is a federal contract, FDIC-insured banks would be considered federal contractors as the bank would accept the insurance. See FAQ #13.
Second, some banks are required to file Affirmative Action Plans via OFCCP’s Contractor Portal. It is anticipated that if a bank is registered through OFCCP’s Contractor Portal or has subscribed to OFCCP’s “GovDelivery” e-mail listserv, the bank can generally expect that OFCCP considers the bank to be a federal contractor and may disclose the bank’s EEO-1 Report data.
In response to the FOIA request, a bank, as federal contractor, need consider whether to file objections with OFCCP regarding the FOIA request for its EEO-1 Report data. OFCCP has also issued a FAQ regarding the FOIA request.
Consider Filing an Objection to the Disclosure of EEO-1 Report Data and Steps for Filing
If a bank filed any EEO-1 Report in 2016–2020, it need consider whether to file an objection with OFCCP over the release of its EE0-1 Report data. As some banks voluntarily report diversity data, the release of EEO-1 Report data may be less of a concern than for those who seek to keep diversity data nonpublic. Again, it is expected that CIR seeks the information for further reporting about the racial, ethnic, and gender composition of federal contractors’ employees.
As stated in the Federal Register notice, OFCCP acknowledges that Exemption 4 of FOIA may provide for OFCCP to withhold specific federal contractor EEO-1 Reports. However, each federal contractor must object to the release if it seeks to protect its EEO-1 Reports from being released under the FIOA request. The written objection must be received no later than September 19, 2022.
To facilitate the process, OFCCP has created a web form through which written objections may be submitted. WBA recommends the use of the specifically created web form. Written objections may also be submitted via email. Regardless of the delivery system used, any objections filed by the bank must include the bank’s name, address, and contact information for the bank.
A bank will need to answer the following six questions. With exception to question #6, WBA recommends banks filing objections to answer “yes” to each question. Banks filing an objection also need to include a description of how the release of its EEO-1 Report data would impact its recruiting efforts, employee retention, and management of its workforce. Banks also need to describe the protections it has in place for maintaining the confidentiality of the data contained in its EE0-1 Reports. Answering the questions and providing descriptions are critical for OFCCP to determine whether the information should be withheld or disclosed pursuant to FIOA Exemption 4.
- Do you consider information in your EEO-1 report to be a trade secret or commercial information? If yes, please explain why.
- Do you customarily keep the requested information private or closely-held? If yes, please explain what steps have been taken to protect data contained in your reports, and to whom it has been disclosed.
- Do you contend that the government provided an express or implied assurance of confidentiality? If yes, please explain. If no, skip to question 4.
- If you answered “no” to question 3, were there expressed or implied indications at the time the information was submitted that the government would publicly disclose the information? If yes, please explain.
- Do you believe that disclosure of this information could cause harm to an interest protected by Exemption 4 (such as by causing genuine harm to your economic or business interests)? If yes, please explain.
- Are there other legal issues OFCCP should be aware of? If yes, please explain.
Summary
A recent FOIA request of OFCCP seeks data from EEO-1 Reports filed by federal contractors from 2016-2020. As a result of the request and of the type of information requested, OFCCP requested that entities (which could include banks) that filed Type 2 Consolidated EEO-1 Reports as federal contractors at any time from 2016-2020, that object to the disclosure of the information, to submit those objections to OFCCP by September 19, 2022.
OFCCP has created a web form for filing objections. If OFCCP does not receive a written objection by September 19, it will assume that the federal contractor has no objection to the disclosure and will begin the process of sending the bank’s EE0-1 Report data to the FOIA requester.
Any follow-up questions to the OFCCP notice may be posed to WBA Legal by email or by phone at 608-441-1200.
By Rose Oswald Poels
Every fall, I travel to Washington D.C. with a small group of bankers to visit regulators. During this trip, we nearly always meet with staff from Consumer Financial Protection Bureau (CFPB).
Since CFPB’s inception, we inevitably encourage the CFPB staff during each of these annual visits to focus more on the non-bank financial organizations that operate in the traditional “banking” space. Nearly every time we have this conversation, they nod and share that they provide this type of supervision typically through a complaint-based system. This means that if enough consumers complain about a particular financial organization (not a regulated bank), they will investigate and take whatever action they deem appropriate. Certainly, this has been incredibly frustrating for bankers to hear over the years given that many non-bank actors contributed to the causes of the Great Recession back in 2008 and 2009 and CFPB’s mission is that of protecting consumers. It has been too easy for CFPB to focus on the banking industry through their rulemaking and enforcement authorities since banks are easier to find with traditional brick-and-mortar offices.
I was pleasantly surprised to learn recently, however, that the CFPB has focused some of its attention on the non-bank financial industry by assessing fines to fintech companies for actions that have ultimately harmed consumers. Specifically, CFPB recently levied a $2.7 million fine against lender Hello Digit for a range of issues including misleading marketing claims such as “no overdraft fees.” This claim of no overdraft fees was one of several promises made to consumers by Hello Digit that were, in fact, not always true. Other fintechs have made similar claims regarding no overdraft fees as well, including digital lender Chime, that have turned out to be misleading or only true in a limited set of circumstances.
At the same time, the FDIC recently issued cease and desist orders against five crypto firms for making false or misleading statements suggesting that their digital assets were FDIC-insured. According to the FDIC, each of these companies made false representations on their website and social media accounts stating or suggesting that certain crypto-related products are FDIC-insured or that stocks held in brokerage accounts are FDIC-insured. As we all know, these representations are false and misleading.
There are many fintechs that are working to do the right thing and help improve the financial industry through technological efficiencies, but some reasonable level of regulation and oversight is important for these institutions just like banks. These recent regulatory actions against non-bank financial organizations are good reminders that it is important to continue sharing our concerns with regulatory agencies related to non-bank actors and to continue to stress to our clients and the public how trustworthy banks are.
If you are interested in accompanying me on a future fall regulatory agency trip to D.C., please let me know and I will add you to the list. I try to keep the group small, limited to 12 bankers, to ensure meaningful dialogue with the regulatory agencies. Bankers who have joined me in the past have found this trip to be worthwhile given much of our frustration and burden comes from regulation. In the meantime, WBA will continue to advocate for the members on these and other issues affecting the industry.
By Rose Oswald Poels
At the heart of the Wisconsin Bankers Association’s (WBA) mission is advocating on behalf of the Wisconsin’s banking industry. In the last year alone, WBA has taken action in combating credit card fees, increasing instances of elder fraud in our communities, legislation that would expand credit union powers, a looming recession, and so much more.
It’s no secret that WBA-member banks play a significant role in the support of our Association. Between political contributions that help further engage our legislators or by participating in Capitol Day, organizing a “Take Your Legislator to Work Day”, or testifying on a bill — the engagement shown by our membership has been paramount in advancing WBA’s efforts over the last 130 years.
I am also lucky to say that, in addition to the thousands of bankers throughout the state who engage with WBA, our Association is also made up of nearly 50 individuals who, like you, are sincerely dedicated to our state’s banking industry.
Earlier this month, WBA hosted its annual staff fundraiser in support of Wisbankpac and Alliance of Bankers for Wisconsin (ABW) — two critical methods of promoting advocacy for the Wisconsin banking industry. This timely event, in which the funds raised are used to help support pro-banking political candidates, welcomed staff donations (though participation was not required) by way of a specified contribution from payroll, a check made out to one of the funds, or the purchase of one or more Jeans Day stickers for a casual dress day at the office. All money raised directly aids in WBA’s advocacy efforts.
For their generosity, and to celebrate Wisconsin’s beloved county fair season, WBA hosted a fair-themed week of events. Ranging from a blue ribbon bake off to games and a cornhole competition, every staff person was able to participate in activities and win prizes.
I am proud to announce that our small but mighty staff was collectively able to crush our goal of $7,000 and raise over $12,350 this year. This amazing feat by our team highlights the commitment each WBA staff member has to the industry and our membership.
As we look ahead to the remainder of this calendar year, it is critical that all WBA-member banks continue to engage with our Government Relations team and take part in supporting our industry. In addition to making political contributions, banks should take a moment to ensure they remain on track to receive WBA’s Gold Triangle or Bankers Involved in Grassroots and Government (BIGG) Award.
The Gold Triangle Club, the highest level of fundraising recognition for banks, is awarded annually through contributions to ABW political conduit, Wisbankpac, or WBA’s issue advocacy fund. Corporate contributions as well as contributions from bank employees and directors count toward Gold Triangle status, and the amount to qualify ranges from $500 to $4,500 based on the size of the bank.
WBA’s BIGG Award expands beyond Gold Triangle fundraising to encompass grassroots advocacy engagement and serves as the Association’s highest level of recognition for overall advocacy. To learn more about how your bank can earn these prestigious awards, please contact Lorenzo Cruz, vice president – government relations, or me.
As I’ve stated in previous publications, the support and involvement of every member bank is critical to the continued success of our advocacy efforts. With the goal of raising $300,000 by the end of this year, it truly requires a team effort to keep our Association on target to continue surpassing our goals for the industry!
By Lorenzo Cruz
The credit card swipe fee debate could reignite as interest rates rise and inflationary pressures persist into 2023. If the sparks fly and catch fire, retailers could reunite to advocate for interchange fee reform, which has severe negative financial consequences for banks, the electronic payments ecosystem, and consumers alike.
The Importance of Interchange Fee
During the last legislative session, a retail coalition led efforts to introduce legislation that would have prevented banks from applying interchange fees on the tax portion of a credit card transaction and would impose a $200 fine per transaction for any entity that violates the law. Similar legislation has been offered across the nation more than forty times over the last 16 years. To date, no state has enacted the legislation, nor has this model legislation made it out of any committee.
Retailers contend this change would provide some relief for tax collection and would lower their second highest expense — credit card swipe fees. Members of the Wisconsin Bankers Association (WBA) empathize with retailers’ concerns, but there are other ways retailers could receive vendor compensation as payment for that work.
Interchange fees remain a critical revenue stream for banks of all sizes in rural and urban markets. The fees allow banks to recover the cost for fraud protection and for cybersecurity that card issuing banks provide to their customers. Retailers and consumers enjoy the credit card fee benefits of a seamless globally accepted transaction and a guaranteed payment that is secure, convenient, and affordable. Retailers also see higher volume and sales from credit card use, faster transactions, lower costs than those associated with handling checks and cash, and more sales channels.
Negative Impacts on Wisconsin
Passage of interchange fee legislation would have negative and impractical implications for the electronic payment system and consumers. Consumers would have to undergo a split tender transaction, being forced to use the credit card for the total sum of goods or services purchased in the first transaction but then would pay in cash or check for the remaining tax portion in a separate transaction. Retailers could see an increase in customer confusion and frustration as the speedy checkout line becomes a distant memory.
Currently, the electronic payment system has no way of separating out the tax piece of the transaction. Financial institutions and card networks only see the full transaction sum when approving, routing, and settling electronic payments. This design protects consumers’ privacy and allows for lightning speed transactions.
Visa’s network alone processes over $12 trillion in transactions annually. Visa has the capacity to handle over 65,000 transactions a second, however, the proposed special tax treatment change would require a major, costly overhaul of the system. The chip conversion for credit cards took over 25 years to research, test, and implement, which goes to show there is nothing simple about making changes to these networks. Wisconsin could easily become an island in the electronic payment space if the legislation passes.
With prices of gas and food increasing and talks of recession afoot, the last thing consumers would want is a legislative change that makes it potentially more difficult to use their card during these challenging times. WBA urges our retail partners and customers to pursue vendor compensation alternatives rather than tinker with the interchange fee in a harmful manner. Additionally, WBA members are encouraged to continue to educate customers and policymakers on the importance of interchange fees to banks and the communities they serve.
The following is a brief interview between WBA President and CEO Rose Oswald Poels and Spring Bank, Brookfield CEO David Schuelke.
Rose: How did you first get into the banking industry?
David: I was born into a banking family. Even though my father, Don Schuelke, was a banker, he didn’t encourage me to pursue a banking career and it wasn’t an original career goal for me. I graduated college with an accounting degree intending to enter public accounting. However, I accepted a good offer from First Wisconsin Bank to start my professional career. At First Wisconsin, I joined an outstanding culture and a talented team of professionals. Those colleagues and that culture led me to want to remain in the banking field.
What is your favorite aspect of your role at your bank?
The most rewarding aspect for me is helping businesses. I’ve always been intrigued and fascinated by different businesses — how they operate, how similar businesses do things differently but all reach success in their own way. It’s also meeting people and the variety. But nothing is better than somebody telling you that you came up with an idea that helped them improve their business.
I also enjoy watching my colleagues advance in their careers and sharing news of our strong financial results with my fellow shareholders. I’m very proud to have played a key role in developing a successful bank — from raising the capital to open to forming a team that executes our business plan of being a locally owned, locally operated bank focused on providing the personal attention our customers deserve.
What do you wish the general public understood about the banking industry?
I wish the public had a better understanding of how banks operate within very narrow interest rate margins and about the costs to maintain the infrastructure needed to deliver high quality service and products. This lack of understanding leads a few clients to expect bank services to be delivered at little or no cost.
Where do you believe the industry’s greatest challenges are in the next three to five years?
Our industry’s greatest challenges include changing technology, a sometimes-oppressive regulatory environment, and potential economic challenges.
Technology will continue to evolve rapidly. Figuring out how to adopt new or changing technologies is a constant challenge. The cost to keep up with regulatory pressures has easily doubled, and possibly tripled or more, since we opened Spring Bank in 2008. Managing these increasing costs and requirements is a big challenge.
Lastly, current levels of inflation, supply chain disruptions, and a shortage of workers have resulted in expectations of a recession after many years of economic growth. When the next recession arrives, banks will need to focus on credit quality and work to resolve problem loan situations that arise. Fortunately, the banking industry is better capitalized today than it was at the start of the last recession.
Every day, bankers serve their local communities by helping their customers achieve their financial dreams. Please describe your current role at your bank and share with us one of your more rewarding experiences.
With regard to community involvement, one of the most impactful days of my life was joining a group of over 100 World War II veterans on a trip to Washington D.C. to view the WWII Memorial as part of the Stars & Stripes Honor Flight program. Spring Bank has supported this effort for many years as part of our pride and appreciation for our nation’s veterans. Speaking with many heroes that day, watching them interact with their peers, and experiencing the welcome home celebration at the end of the day is a memory I will never forget.
By Rose Oswald Poels
Since the Wisconsin Bankers Association’s (WBA) inception 130 years ago, advocating on behalf of Wisconsin bankers has been one of our top priorities. WBA reaches across aisles, supporting pro-banking legislators and candidates, with the goal of advocating for and supporting the banking industry.
With Wisconsin’s general election quickly approaching in November and the primary just next week on August 9, I wish to remind all Wisconsin bankers of the importance of not only participating in these two elections, but ultimately making your voice heard on behalf of our industry.
This year, the American Bankers Association (ABA) is once again promoting their “Get Out the Vote” initiative which assists in educating voters on banking issues. I encourage you to visit the ABA’s site to make sure you are registered to vote, know the candidates on your ballot, and where your polling locations are. ABA has also created a toolkit for banks to share with employees to promote voter participation.
As we know, Wisconsin’s election battleground regularly takes the national spotlight and with candidates looking to flip the ballot for several major state offices — Governor, U.S. Senate, and some state Assembly seats, to name a few — little is expected to change this year. In addition to making your voice heard through casting your vote next week (and in November), I encourage bankers to actively participate in our advocacy initiatives in two additional ways.
Take Your Legislator to Work
As WBA’s over 100 Advocacy Officers can attest, the most effective way of advocating for our industry is to meet with legislators in person. Taking this one step further, “Take Your Legislator to Work Day” visits not only allow decision makers to hear about the great work bankers do each day in their communities but see it for themselves.
Your direct involvement in hosting legislators not only assists our elected government officials in further understanding the community banking industry and the impact legislation has on our operations, but also offers an in-depth perspective into Wisconsin’s economy as well as the successes and challenges many of our communities face.
The WBA Government Relations team stands ready to assist your bank in engaging in advocacy-related events, including working with you to schedule a “Take Your Legislator to Work Day” at your bank. If you would like to host, or learn more about hosting a visit, please contact Lorenzo Cruz, vice president – government relations, or me.
Political Contributions
WBA is not concerned with “D” or “R”, but rather “B” as in the “Banking” party. Donating to WBA’s political action funds in support of pro-banking candidates is an easy and significant way to further promote WBA’s legislative agenda and bankers throughout the state.
Wisbankpac is WBA’s registered political action committee. Wisbankpac supports pro-banking candidates throughout Wisconsin by pooling individual banker contributions in order to maximize the overall impact. The Alliance of Bankers for Wisconsin (ABW) — WBA’s state conduit — allows individuals to direct contributions to the candidate(s) of their choosing.
I greatly appreciate your past support and active involvement in WBA’s various advocacy initiatives; however, as with everything else, we need your engagement to continue at an even higher level. It would be ideal if an additional six to eight “Take Your Legislator to Work Day” visits were scheduled between now and December. Furthermore, WBA has a goal of raising $300,000 in our political accounts this calendar year, which will require greater participation than what has occurred in the past. If you are interested in contributing to WBA’s political action funds — be it Wisbankpac or ABW — or learning more about how to contribute, please visit wisbank.com/Give or contact me. Together we will continue to achieve successes for our industry!