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.
Wisconsin bankers prepare for forthcoming legislation, guidance
By Hannah Flanders
An increasing number of Wisconsinites are growing concerned about climate change and its effects on the state’s key economic sectors — agriculture and forest product, fisheries, and outdoor tourism and recreation. Each year, these sectors continue to be negatively impacted as a result of increasing temperature, humidity, precipitation, and extreme weather events.
In an effort to preserve America’s unique, natural resources, promote public health and safety, and extend the positive growth in our economies, regulators across the country have turned their focus to understanding climate-related financial risks. In January 2021, President Joe Biden issued an Executive Order relating to protecting public health and the environment. As a result, many key banking regulators and Wisconsin officials have announced advisories, statements, and proposals of their own to aid banks and other industries in mitigating the effects of climate change on the economy.
Ensuring Consistency
As sectors and jurisdictions in the financial system become increasingly more intertwined and supervisory and regulatory authorities continue to assess climate-related financial risks, the Financial Stability Board (FSB) has published draft recommendations in an effort to promote consistency throughout the financial system as well as to assist financial institutions in managing and mitigating climate-related risks. Final recommendations from the FSB are expected in the fourth quarter of 2022.
The Financial Stability Oversight Council (FSOC), in addition to establishing the Climate-related Financial Risk Committee (CFRC) which assists in identifying, assessing, and mitigating climate-related risks to the financial system and developing common approaches and standards, the Council has recently released recommendations to FSOC members — including the U.S. Securities and Exchange Commission (SEC), the Federal Reserve Board (FRB), and the Federal Housing Financing Agency (FHFA) — regarding their action on climate change data, disclosure, and scenario analysis.
While several agencies, including SEC and the Office of the Comptroller of the Currency (OCC), have already acted on risks related to climate change, Acting Director of the FHFA Sandra L. Thompson said in a statement released in December 2021 that FHLBanks are encouraged to designate climate change as a priority and actively consider its effects in their decision
making. The FHFA also created a new Conservatorship Scorecard which assesses Fannie Mae, Freddie Mac, and Common Securitization Solutions on their ability to promote sustainable and equitable access to affordable housing while operating in a safe and sound matter.
Proposed Federal Legislation
Both the OCC and the Federal Deposit Insurance Corporation (FDIC) have issued draft principles that provide framework for the management of climate-related financial risks by banks with more than $100 billion in total consolidated assets.
Although either draft has yet to be finalized, the Wisconsin Bankers Association (WBA) issued a comment letter in June to members of the FDIC warning of the potential negative impact this draft may unintentionally have on smaller, community banks and the communities they serve.
In addition to commenting on the FDIC’s draft principles, WBA joined the Independent Community Bankers of America (ICBA) and several state banking associations from around the country in expressing concerns related to the FDIC’s proposed statement of principles highlighting the effects of large financial institutions being pressured or required to “de-risk” their loan portfolios. The ruling in its current state has the potential of excluding lawful but climate disfavored customers or industries from the financial system.
This year, the SEC has also proposed two climate-related disclosure rulings that Wisconsin bankers should consider for investment purposes. The first proposal — the Enhancement and Standardization of Climate- Related Disclosures for Investors — focuses specifically on requiring registrants to include certain climate-related disclosures in their registration statements and periodic reports.
While the approach to release climate-related disclosures through existing SEC requirements is appreciated, in its comments, WBA highlighted that Wisconsin’s financial institutions, publicly traded or not, have successfully managed credit-based risk for decades and that this proposal is primary built on supplying non-financial information that many businesses do not have the resources to provide.
In addition to recommending that SEC repeal said proposal in its own comments, the Association joined nearly 100 supporting groups in signing onto the House Small Business Committee’s Republican-led letter to SEC demanding the rescission of the proposed ruling.
The second — Enhanced Disclosures by Certain Investment Advisers and Investment Companies About Environmental, Social, and Governance (ESG) Investment Practices — amended the ruling and forms under the Investment Advisors Act and the Investment Company Act. This would require certain advisers, investment companies, and business development companies to provide additional information regarding their ESG investment practices. Comments on this ruling were due August 2022.
Wisconsin-Specific Efforts
In Wisconsin, Governor Tony Evers has highlighted combatting climate change is a key priority for the administration. Earlier this year, the Governor’s Task Force on Climate Change — a coalition of representatives from industries and communities across the state — recommended the creation of the Office of Environmental Justice within the Department of Administration (DOA).
The Office, supported by the first state-level chief resilience officer (CRO) in the Midwest — now serves as the state’s principal office in coordinating agency frameworks, strategies, and policymaking to ensure state action does not have an adverse or disparate environmental effect on under-resourced communities.
Additionally, the Wisconsin Department of Financial Institutions (DFI) has so far only released an ESG investing advisory which includes an overview of its effects and what investors should consider. However, as climate-related risk becomes an increasing concern for industries and communities across the state, Wisconsin bankers should expect that state-level advisories, guidance, or legislation may be forthcoming.
While no hard and fast ruling yet stands for banks related to climate-related risk disclosures either at the federal or state levels, WBA advises bankers to be aware of the potential for upcoming regulation on the topic.
View WBA’s recent comment letters by visiting wisbank.com/CommentLetters. For questions on legal developments or regulations related to climate change or other compliance matters, please reach out to WBA legal at wbalegal@wisbank.com or 608-441-1200.
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.
By Rose Oswald Poels
When WBA’s charitable arm, the Wisconsin Bankers Foundation (WBF), was founded in 2015, education remained a top priority to aid the public in increasing their financial literacy and responsibility.
As part of this, the Foundation is proud to offer well-known programs such as Reading Raises Interest Kits that assist bankers in coordinating curriculum used during Teach Children to Save Day in April and scholarships awarded to students throughout the state for their demonstration of excellent financial capabilities. Involvement in these programs brings the Foundation one step closer to ensuring the financial knowledge and responsibility of every youth in our state.
Now through November 15, the Foundation will be accepting applications for the third annual Agricultural Banking Scholarship!
Students who will be enrolled in an accredited Wisconsin college, university, or technical college during the Spring of 2023 and are pursuing a career related to agricultural banking are encouraged to apply.
With agriculture serving as one of Wisconsin’s largest economic drivers, it is critical that we invest now in the students that are interested in driving this critical sector of our state.
The Foundation is also excited to announce this year’s Agricultural Banking Scholarship award has been increased to $1,500 each for the two qualified winners in order to help combat rising tuition costs, assist individuals in reaching their goals, and promote financial literacy in every consumer.
I encourage you to share this exciting opportunity widely within your networks — current and past ag interns, parents of college-aged children, and educators at the many ag programs throughout the state. By aiding us in spreading the word to qualified students, you play a significant part in assisting the Foundation to serve its mission as well as provide new opportunities for your community!
Please visit wisbankfoundation.org/scholarships to learn more or contact WBF’s Foundation Coordinator Hannah Flanders with any questions.
Pictured left to right are: Lee J. Schmalz, John K. Reinke, and Robert J. Just, Jr.
Five individuals were honored by the Wisconsin Bankers Association for their excellence in banking, community service, and civic involvement. A celebration was held on Friday, September 9 at the WBA headquarters in Madison, where a Leaders in Banking Excellence Wall installation displays a tribute to outstanding current and former bankers. The wall, established in 2020, now profiles 22 exceptional leaders.
“This year’s Leaders in Banking Excellence are once again deserving of the name,” said Rose Oswald Poels, WBA president and CEO. “These five bankers have not only been influential in their profession but have also been actively involved in their communities throughout their careers.”
The honorees in the Class of 2022 Leaders in Banking Excellence are:
- Robert J. Just, Jr., Mound City Bank, Platteville;
- Debra R. Lins, the former Community Business Bank, Sauk City (and others);
- John K. Reinke, The Stephenson National Bank & Trust, Marinette;
- Lee J. Schmalz, East Wisconsin Savings Bank, Kaukauna; and
- the late James B. Wigdale, M&I Bank (now BMO Harris Bank), Milwaukee.
To read the bios of each of the 2022 Leaders in Banking Excellence honorees, please visit the Class of 2022 page.
By Rose Oswald Poels
As our Association continues its efforts to support bankers of historically underrepresented backgrounds, finding new ways to invest in the personal and professional development of every one of our employees is top of mind.
WBA’s employee resource group (ERG), which launched in June, continues to provide a safe space for our colleagues of color and individuals of underrepresented backgrounds to engage in employee-led conversations once a month related to their identity or feelings, ideas, and developments in the diversity, equity, and inclusion (DEI) space.
The next meeting will be held Thursday, September 22 at 10:00 a.m. The conversation will include the topic of professionalism and an open discussion with staff from Peoples State Bank, Wausau regarding their involvement with the local Hmong community. Bank leaders, managers, and HR professionals are encouraged to forward this opportunity on to bankers who may benefit from this inclusive forum.
Additionally, in conjunction with WBA’s DEI Plan to provide professional development opportunities and foster a welcoming, inclusive culture, I am excited to announce that WBA will be offering three educational scholarships to select WBA events this fall.
These scholarships, offered in partnership with the Federal Home Loan Bank of Chicago, will be presented to bankers of historically underrepresented backgrounds — including, but not limited to, individuals of African American/Black, Asian/Asian American/Desi, Indigenous, Hispanic/Latinx/Spanish origin; members of the LGBTQ+ community, people with disabilities, and those part of a religious minority. Please share this scholarship opportunity with members of your staff as they look to expand their career within the banking industry.
WBA’s three educational scholarships will cover the registration fee of the selected program along with any overnight accommodation, as needed.
Scholarships are available for:
- WBA Commercial Lending School (apply by September 16)
- October 12–14, Madison
- WBA BOLT Winter Leadership Summit (apply by September 30)
- November 9, Wisconsin Dells
- WBA LEAD360 Conference (apply by September 30)
- November 16–17, Wisconsin Dells
I encourage bankers to take this chance to invest in their professional development and share these various opportunities with members of their staff. It is ever so important for the prosperity of our banks and the communities in which they serve that individuals of all backgrounds and experience levels are supported in their pursuit of new degrees of leadership and opportunities to expand their career and network.
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 Daniel J. Peterson
As technology continues to advance faster than ever before, the importance of staying up to date on the latest trends and best practices for the safety of both the bank and its customers is quickly becoming the number one concern for Wisconsin bankers.
As the last several years have shown, a growing number of consumers throughout the state rely on technology and online banking for their day-to-day needs. It is critical that, for continued success and relevance of our industry, bankers are aware of not only how best to serve our customers through offering modern banking amenities, but how to best protect our communities from increasingly more sophisticated — and prevalent — fraudsters.
For this purpose, in addition to ensuring that all Wisconsin banks remain a safe, secure place for finances and sensitive information, the Wisconsin Bankers Association (WBA) will once again host a combined Secur-I.T. & BSA/AML Conference. The conference specifically targets BSA/AML, operations, security, and technology banking professionals looking to remain educated on our ever-evolving industry.
This year’s annual conference will be held September 20 and 21 at Glacier Canyon Lodge in Wisconsin Dells and features a unique variety of speakers. From local professionals and WBA Associate Members to world-famous cyber security expert and ethical hacker Bryan Seely, WBA’s Secur-I.T. & BSA/AML Conference will assist banking teams in understanding how best to protect against hackers, what trends to watch for in money laundering, and so much more. This is an event you don’t want to miss!
By engaging in conferences such as WBA’s Secur-I.T. & BSA/AML Conference, bank leaders can ensure their staff is gaining the most relevant and up-to-date banking-related information from the most knowledgeable individuals in the industry. Along with over seven hours of presentations focused on the safety and security of our banks and customers, bankers will enjoy networking with professionals from across the state and meeting with exhibitors offering products and services that help community banks further advance their customer service capabilities.
Please visit wisbank.com/Secur-IT to register or for additional details.
Peterson is president and CEO of The Stephenson National Bank & Trust, Marinette, and the 2022–2023 WBA Chair.
By Daryll J. Lund
In today’s competitive job market, it is ever so important that Wisconsin banks establish themselves as businesses that ensure every employee is set up for success — professionally and personally. As members of the Wisconsin Bankers Association (WBA), banks throughout the state are eligible to join WBA’s Employee Benefits Corporation (WBA EBC) for a wide range of benefit plans that offer employees peace of mind and incentives to save.
Through WBA EBC’s Association Health Plan (AHP) serviced by UnitedHealthcare (UHC), employees of Wisconsin banks have the ability to access competitively priced, flexible medical and vision coverage. Individuals are also able to add motivating incentive programs — such as Motion and Rally — that help inspire healthy habits and save money!
Rally, a wellness program offered through the AHP, motivates employees to meet their lifestyle goals. Alongside other individuals or at their own pace, Rally’s “missions” offer challenges that assist individuals in reaching — and surpassing — lifestyle goals, including eating healthier and increasing movement.
Employees are also able to redeem “Rally Coins” for purchases from fitness, entertainment, and well-being brands upon completion of goals. With an easy-to-use interface and motivating rewards, wellness is made more exciting and achievable for everyone.
Motion is a health savings account (HSA) offered through the WBA EBC’s AHP. The HSA incentivizes walking and meeting goals as an additional way to earn credits. Employees earn a $55 credit upon registration and every credit earned can be deposited into an HSA that assists in reducing out of pocket costs for eligible healthcare expenses. Each year, Motion participants have the ability to save up to $1,095.
Now’s the time to make certain every member of your team is reaching their full potential and saving money while doing so. WBA EBC’s AHP serviced by UHC offers wellness programs that provide great incentives to developing and sustaining good health practices and preventative care, in addition to assisting employees in saving for life’s emergencies.
To learn more about WBA EBC’s insurance options, please contact Brian Siegenthaler, WBA EBC vice president, at 608-441-1211.
