In a recent comment letter, WBA wrote about the proposed regulations affecting deduction for qualified business income.

Section 199A of the Tax Cuts and Jobs Act (TCJA) permits a deduction of up to 20 percent of qualified business income (QBI) from a domestic business operated by certain entities. A specified service trade or business (SSTB) is not a qualified trade or business. The definition of SSTB includes financial services, such as services provided by financial advisors, investment bankers, and wealth planners. On August 16, 2018 the Department of the Treasury proposed regulations creating a de minimis standard for classification of an SSTB.

For a trade or business with gross receipts of $25 million or less for the taxable year, a trade or business is not an SSTB if less than 10 percent of its gross receipts are attributable to the performance of services in an SSTB. For a trade or business with gross receipts of greater than $25 million for the taxable rules, a trade or business is not an SSTB if less than 5 percent of its gross receipts are attributable to the performance of services in an SSTB.

The de minimis threshold creates uncertainty whereby if all the fiduciary activities of a bank were an SSTB, bank would not meet the above threshold, potentially exempting all of the bank’s income from the benefit of the 20 percent QBI deduction. In its comments, WBA urged clarity on this point, so that Wisconsin banks could benefit from the deduction as intended by Congress.

By, Eric Skrum

The September 2018 edition of the WBA Compliance Journal has been published.

This month's Special Focus articles discuss FinCEN's exceptive relief from Beneficial Ownership requirements, and CFPB's implementation of the S. 2155 HMDA partial Exemption. Regulatory Spotlight includes an interim final rule on expanded examination cycles and final amendments to Reg P's annual privacy notice requirements. Compliance Notes includes FDIC's proposal to retire certain Financial Institution Letters.

Click here to download the September 2018 Compliance Journal.

By, Ally Bates

The Bureau of Consumer Financial Protection (CFPB) has issued an interpretive and procedural rule implementing and clarifying changes to HMDA made by S. 2155 The Economic Growth, Regulatory Relief, and Consumer Protection Act (Act or S.2155). S. 2155 was signed into law May 24, 2018, the Act amends HMDA by adding partial exemptions from HMDA’s requirements for certain transactions made by certain financial institutions. The Act also increases the HMDA reporting threshold to 500 open-end lines of credit, meaning institutions that originated fewer than 500 open-end lines of credit in the two preceding calendar years do not need to collect and report certain data.

This new rule clarifies which data points in HMDA’s Regulation C are covered by the partial exemptions and that only loans and lines of credit that are otherwise reportable under the Regulation count toward the thresholds for the partial exemptions.

S. 2155 also provides that the above partial exemptions are not available to institutions that have received a CRA rating of “needs to improve record of meeting community credit needs” in each of their two most recent CRA examinations, or a rating of “substantial noncompliance in meeting community credit needs” in their most recent exam. The rule clarifies that the CRA examination assessment that would disqualify an institution from the partial exemptions must be made as of December 31 of the preceding calendar year.

CFPB also addresses transition issues with the implementation of the rule. The rule applies to data collected or reported under HMDA on or after May 24, 2018. An institution that is eligible for a partial exemption for a transaction does not need to collect exempt data points on or after May 24, 2018. In addition, such institutions are not required to report certain data that may have been collected on or before May 24, 2018. However, an institution may opt to voluntarily report data that are covered by a partial exemption.

The rule will be effective Sept. 7, 2018.

Click here for the full rule.

Click here for the executive summary.

By, Ally Bates

Dane County – Banks are the backbones of their communities, supporting them in difficult times. The recent flooding in southern Wisconsin is no different. Several banks have taken important steps to help their friends and neighbors in the wake of the historic rainfalls and flooding affecting many communities.

  • The Peoples Community Bank, Mazomanie, has established the Mazomanie Area Flood Assistance Fund (
  • The State Bank of Cross Plains has orchestrated a Disaster Recovery Account in connection with the United Way (, as well as coordinated and volunteered in wide-ranging relief efforts in the bank’s communities. Additionally, the bank is providing impacted employees $500 in cash, directly deposited into their account, no questions asked.
  • Wisconsin Bank and Trust, Madison, will be donating $5 to the American Red Cross for each person who visits their Main, Fitchburg, or Cottage Grove Banking Centers, up to $2,500.00.
  • Monona Bank, Monona, has established two funds to help those affected by the ongoing flooding and storm issues. Donations for either fund can be sent to or dropped off at any of the bank's nine locations. The first account created is for donations that will be used to help people in the bank's communities all around Dane County. The bank has already committed more than $10,000 to this fund and many of the bank’s board members are also contributing as well. Checks should be made out to “Dane County Area 2018 Flood Relief Fund.” The bank has also opened an account to help one of its clients, the Prochaska family who lost their entire house and contents when lightning struck their home last week. Checks for this fund can be made out to “Daniel or Doretta Prochaska”
  • Farmers State Bank, in conjunction with Organic Valley, established a Flood Disaster Recovery fund to be distributed to local organizations for Vernon, Juneau, Richland, Sauk, and Monroe counties. Farmers State Bank and Organic Valley are each donating to this fund an initial $1,000. To contribute to this fund, checks should be made out to "Farmers State Bank Flood Disaster Fund" and can be dropped off at any branch or mailed to Farmers State Bank P.O. Box 405 Hillsboro, WI 54634. Funds will be distributed to local 501c3 organizations or per the recommendations of county's Emergency Management Department. 
  • Farmers & Merchants Bank, Tomah, has opened a Disaster Recovery Account for Monroe County ( and the bank will match the first $1000 donated. The bank is also donating to another community business' "Stuff the Trailer" initiative to collect cleaning supplies, bottled water, and non-perishable food items.
  • Community First Bank, Boscobel, donated $10,000 to the Greater Sauk Community Foundation for those affected and displaced here in Sauk County.
  • Royal Bank, Elroy, teamed up with the La Valle Fire Rescue to establish the La Valle Area Flood Relief Fund. All proceeds will benefit local residents and businesses of the La Valle area impacted by the flooding. Donations can be made at any Royal Bank location or mailed to Royal Bank, PO Box 5, La Valle, WI 53941. Checks should be made payable to La Valle Area Flood Relief Fund or to La Valle Fire  Rescue with a designation to the La Valle Area Flood Relief Fund. 

Several banks (including some listed above) are also offering special low- or no-cost loans to those impacted by the flooding. Those affected by the floods should contact their local bank for more details on these services.

It should be noted that several banks and their employees have been impacted by the flooding, as well. Despite these challenges, the banks have made strong efforts to care for the needs of their communities. The Wisconsin Bankers Association commends banks for taking these steps to help in the recovery efforts of their friends and neighbors.

Community banks have always been and will continue to be an integral part in assisting their communities during times of need. We are proud to serve the banking industry because of the way they serve their communities. The above-mentioned banks are simply the latest examples of this community dedication.

By, Ally Bates

The August 2018 edition of the WBA Compliance Journal has been published.

This month's Special Focus article discusses Wisconsin’s Industrial Hemp Pilot
Research Program. Regulatory Spotlight includes proposed amendments to the Bank Holding Comapny Act and final amendments to Reg P's annual privacy notice requirements. Compliance Notes addresses the comment letter from the ABA that WBA signed on to.

Click here to download the August 2018 Compliance Journal.

By, Ally Bates

FOR IMMEDIATE RELEASE                                                                            
August 23, 2018

For more information, contact:
Ally Bates, Wisconsin Bankers Association
608-441-1207 |
Twitter: @wisbank

Statement on the release of second quarter 2018 FDIC numbers from Rose Oswald Poels, president/CEO of the Wisconsin Bankers Association

“Wisconsin banks continue to perform strongly overall per the latest FDIC quarterly numbers.

Lending continues to grow in a year-to-year analysis with commercial lending showing the biggest growth (8.0%), and farm loans showing the second most growth (6.7%). Total deposits grew 4.8% to over $90 million, while noncurrent loans decreased 6.7% since second quarter 2017.

These latest FDIC numbers continue to highlight the fact that Wisconsin banks remain committed to helping businesses grow and families prosper, creating thriving communities. 

Wisconsin’s banking industry reflects Wisconsin’s current healthy economy as well as the overall national trends. Overall bank employment increased 1.2% from 2017, indicating banks are generally optimistic about the future. Businesses, including banks, in Wisconsin have benefitted from federal tax reform, but bankers are expected to remain watchful on credit quality issues.”

FDIC Reported WI Numbers*





Total Loans & Leases



+ 4.3%

Total Deposits



+ 4.8%

Commercial & Industrial Loans



+ 8.0%

Residential Loans



+ 3.3%

Farm Loans



+ 6.7%

Farmland Loans



+ 4.8%

Total Assets



+ 4.0%

Noncurrent Loans & Leases



– 6.7%

* dollar figures in thousands


The Wisconsin Bankers Association is the state’s largest financial industry trade association, representing nearly 240 commercial banks and savings institutions, their nearly 2,300 branch offices and 23,000 employees.

By, Ally Bates

Markesan State Bank is pleased to announce the hiring of Megan Connor. Connor joins the lending team as a Consumer/Residential Lender in our Randolph Branch. Her primary areas of lending will be focused on Residential and Consumer Lending.

Connor comes to Markesan State Bank with over 7 years of mortgage lending experience. 

Connor holds an Associate’s degree from Madison Area Technical College and comes to us with a vast knowledge of the mortgage lending industry. She is excited about taking her knowledge and skills to assist people in finding and creating their dream homes.

Connor grew up south of Madison, WI and moved to the Fox Lake area in 2010. She enjoys supporting her children in their school related activities, gardening, and restoring classic trucks.

View Bulletin Board.

By, Ally Bates

WBA continues to monitor the implementation of the Wisconsin Department of Health Services (DHS) updated Medicaid Asset Verification Data Matching program (AVS). In July 2017, DHS informed WBA that AVS was being temporarily suspended due to the expiration of the contract between DHS and its data match vendor Health Management Systems Inc. DHS has selected a new vendor, Accuity Asset Verification Services, and sent out a letter with more information Monday, April 9, 2018.

Accuity Asset Verification Services sent emails to Wisconsin financial institutions on Friday, April 27. These emails are valid, and part of the AVS implementation process. WBA has since spoken with DHS and learned that these emails went to previous contacts Accuity Asset Verification Services had with each individual financial institution. As a result, the email may have been missed. 

DHS is implementing AVS next month, and Accuity Asset Verification Services will follow up with another email next month to correspond with the implementation. If a financial institution has not received the April 27 email, WBA recommends reaching out directly to or 855-807-9822. DHS has also informed WBA that financial institutions may contact Autumn Arnold at

By, Eric Skrum

"First and foremost, we would like to thank Paul for his service to this state and our nation over the past 20 years. He represented Wisconsin admirably during his entire tenure in the House, demonstrating remarkable leadership during difficult times. He was instrumental in providing stability and direction during the financial crisis, and his hard work and leadership were integral in passing recent tax reforms that provide much-needed relief to consumers and businesses. 

His ability to promote compromise and unity will certainly be missed in Washington. We wish Paul the best of luck in his future endeavors."

By, Amber Seitz

The Wisconsin Bankers Association offers for your use the following consumer education column. Your bank is free to use this as a community column in your local newspaper, a letter to the editor, a press release or in any other way you see fit. The purpose is to give our members an easy-to-use tool for promoting the banking industry to Wisconsin’s communities.

New Year, New Me, right? We’re a few weeks into the new year and you may have dropped your New Year’s Resolution to become financially fit. Don’t despair. It’s still early in the new year and a great time to clean up your financials, adopt better spending habits, and start saving more. Here are a few tips to keep in mind:

Make a budget and stick with it
This almost cliché financial advice is repeated so often for one important reason: it works. Start by tracking your spending, once you’ve tracked how much money you spend over the course of a few weeks, you can look for trends in what you’re spending. These trends help you start planning on how much income goes towards necessities (like rent/mortgage, utilities, groceries), and see areas where you can cut back (rarely-used subscription services, eating out less) and start putting away a portion of your income towards a savings goal. The most important part of a budget is sticking with it, once you start tracking your spending you should make sure to take time every day or every few days to log your spending and compare that to your planned spending.

Deal with any debt
Debt is an extremely stressful thing to deal with but the new year is a time to get a handle on any debt that may have piled up around the holidays. Debt should be something factored into your budget like your electric bill and tracked. Although it may be daunting, contact your creditors to discuss your situation, they may be willing to work with you to put together a repayment plan. If you're carrying debt on multiple credit cards, talk to your local bank about the possibility of consolidating that debt into a single payment so you can close the extra card accounts. No matter what you do, addressing debt instead of ignoring it will help you get a handle on it and make positive progress.

Shop around
Many times people will stick with whatever they find first, be it their internet provider, car insurance, or brand of soup, but that may not be the best deal, especially a few years down the line. There’s nothing wrong with being loyal to a company but just because they’ve been your cable provider for a few years isn’t necessarily a good reason to stay with them and doesn’t ensure that you are getting the best value for what you are paying. Look around to see what other companies are charging for similar services, you may find that your current company is priced competitively or you may find that you can get a better deal elsewhere. One thing to beware of is a cheaper product or service that is cheaper for a reason, make sure you are still getting a similar quality or ask yourself if you are ok with a downgrade.
Making a commitment to financial health and wellness can be a great way to start the New Year on good footing that can last throughout the year and your life.   

An archive of Consumer Columns is available online at

By, Eric Skrum