• Home
  • Education
  • News and Resources
  • Advocacy
  • Associate Members
  • Contact
  • Click to open the search input field Click to open the search input field Search
  • Menu Menu
News
Advocacy, News

Executive Letter: Regulatory Advocacy in Action

By Rose Oswald Poels

Last week, 12 bankers joined WBA’s Heather MacKinnon, VP – legal, and me in Washington, D.C. for our annual trip to meet with regulators. This trip is always a productive one, resulting in impactful advocacy and conversations given the smaller group size. In the span of only two half-days, our group was able to meet with senior officials from the Federal Reserve, FDIC, OCC, CFPB, FinCEN, and FHFA. The topics we covered in detail included representment fees, bank capital/liquidity, Section 1071, Section 1033, beneficial ownership, FHLB reform, cybersecurity, and other top examination concerns.

Our conversation with Fed Governor Miki Bowman focused on the Fed’s recent compliance bulletin published last month noting that Fed member banks are now being cited with an unfairness UDAP violation if they are charging representment fees. This retroactive application of the Fed’s new expectation as it relates to these fees is creating results that are unjust and wrong. Furthermore, it is also wrong to be creating new rules for banks to follow through the mere issuance of a compliance publication rather than following the formal Administrative Procedures Act rulemaking process. Governor Bowman was surprised to hear of the retroactive nature of these exam findings and agreed to continue to talk with WBA and affected banks about the matter. If you are a Fed member bank and have received a similar finding in your recent exam reports, please let me know and we will include you in our follow-up conversations with the Fed.

Back in April of 2022 when the FDIC first published its new expectations regarding NSF and representment fees in a guidance document, many bankers and trade associations including WBA advocated against any retroactive application of their new interpretation, among other concerns. This resulted in the FDIC eventually adjusting its focus in exams to be prospective only in nature, and to our knowledge did not cite anyone for an unfairness UDAP violation. In our conversations last week with senior FDIC officials, it sounded as though the FDIC may now begin issuing unfair UDAP violations as well. FDIC Director Jonathan McKernan also shared his thoughts with our group around lessons learned from the bank failures earlier this year, encouraged bankers and WBA to comment on the impact the BASEL capital proposal could have on mortgage operations, and supported the role of community banks in fostering an innovative economy.

Previous Previous Previous Next Next Next
123456
Fed Governor Miki Bowman Open image in lightbox: Fed Governor Miki Bowman Open image in lightbox: Fed Governor Miki Bowman
FDIC Director Jonathan McKernan Open image in lightbox: FDIC Director Jonathan McKernan Open image in lightbox: FDIC Director Jonathan McKernan
OCC Acting Comptroller Michael Hsu Open image in lightbox: OCC Acting Comptroller Michael Hsu Open image in lightbox: OCC Acting Comptroller Michael Hsu
Group photo outside White House Open image in lightbox: Group photo outside White House Open image in lightbox: Group photo outside White House
CFPB senior officials Open image in lightbox: CFPB senior officials Open image in lightbox: CFPB senior officials
Group photo on rooftop Open image in lightbox: Group photo on rooftop Open image in lightbox: Group photo on rooftop

Much of the focus of our conversation with OCC Acting Comptroller Michael Hsu was on safety and soundness matters, including the need for banks to stress test their liquidity contingency funding plans and analyze how “sticky” and stable banks’ deposits really are.

With senior officials from CFPB, among other topics, we stressed the industry’s frustration with the Agency’s and Administration’s continued use of “junk fees” to describe fees that are fully disclosed in transparent ways — often on bank websites — in advance to consumers. We discussed beneficial ownership operational concerns at length with FinCEN officials, and learned from the FHFA that their document on FHLB reform will be released “soon.” Overall, the conversations with all six agencies were very productive.

I would like to thank the following bankers for joining WBA this year: Adam Bellmer, Johnson Financial Group; Dave Feldhaus, Federal Home Loan Bank of Chicago; Kristen Gagliano, North Shore Bank; Donna Hoppenjan, Mound City Bank; Corey Hoze, Associated Bank; Caryn Langolf, Bank First; Tom Mews, First National Community Bank; Ryan Kamphuis, Bristol Morgan Bank; Greg Ogren, Security Bank Shares; Dan Peterson, The Stephenson National Bank and Trust; John Udvare, The Equitable Bank; and Theresa Wiese, First Business Bank. If you are interested in joining WBA on this trip next October, please let me know!

Print 🖨
October 25, 2023/by Hannah Flanders
Tags: Executive Letter, Regulatory News
Share this entry
  • Share on Facebook
  • Share on X
  • Share on WhatsApp
  • Share on Pinterest
  • Share on LinkedIn
  • Share on Tumblr
  • Share on Vk
  • Share on Reddit
  • Share by Mail
https://www.wisbank.com/wp-content/uploads/2021/09/Triangle-Backgrounds_Blue-on-Lime-Green.jpg 972 1920 Hannah Flanders https://www.wisbank.com/wp-content/uploads/2021/09/Wisconsin-Bankers-Association-logo.svg Hannah Flanders2023-10-25 15:52:222023-10-25 15:53:01Executive Letter: Regulatory Advocacy in Action
You might also like
Executive Letter: Happy New Year – 2025 Brings Adjusted Regulatory Thresholds
Executive Letter: 2023 Agencies Risk Perspectives
Executive Letter: 2025 Economic Outlook – Insights Across Industries
Executive Letter: Building a Brighter, More Secure Future for Wisconsinites
Executive Letter: New Attempts by California Law Firm Allege Accessibility Violation of Bank Websites
Juneteenth flag Quick Signage Making Juneteenth a Federal Holiday Raising Questions under TILA
Executive Letter: A Sneak Peek at the Society of Bank Executives
Street view of Wisconsin State Capitol building Executive Letter: Taking the Lead on Advocacy
Search Search

Categories

  • Advocacy
  • Community
  • Compliance
  • Credit Unions
  • Education
  • Member News
  • News
  • Products
  • Resources
  • Uncategorized

Recent Posts

  • Chair’s Column — Relevance in a Changing World: A Vision for Community Banks and WBA
  • Associated Bank Adds Chris Sager as Senior Vice President, Private Banking Group, Manager of Professional Services
  • North Shore Bank Pewaukee Parking Lot Initiative Raises Funds for the Pewaukee Predators’ Girls Select Fast Pitch Softball Program
  • Inside the Fight Against Fraud: Highlights From WBA’s First Fraud Summit
  • Association Update: Staying Relevant in a Rapidly Changing Industry

Archives

  • July 2025
  • June 2025
  • May 2025
  • April 2025
  • March 2025
  • February 2025
  • January 2025
  • December 2024
  • November 2024
  • October 2024
  • September 2024
  • August 2024
  • July 2024
  • June 2024
  • May 2024
  • April 2024
  • March 2024
  • February 2024
  • January 2024
  • December 2023
  • November 2023
  • October 2023
  • September 2023
  • August 2023
  • July 2023
  • June 2023
  • May 2023
  • April 2023
  • March 2023
  • February 2023
  • January 2023
  • December 2022
  • November 2022
  • October 2022
  • September 2022
  • August 2022
  • July 2022
  • June 2022
  • May 2022
  • April 2022
  • March 2022
  • February 2022
  • January 2022
  • December 2021
  • November 2021
  • October 2021
  • September 2021
  • August 2021
  • July 2021
  • June 2021
  • May 2021
  • April 2021
  • March 2021
  • February 2021
  • December 2020
  • November 2020
  • October 2020
  • August 2020
  • July 2020
  • June 2020
  • May 2020
  • April 2020
  • March 2020
  • February 2020
  • November 2019
  • October 2019
  • September 2019
  • August 2019
  • July 2019
  • May 2019
  • April 2019
  • March 2019
  • November 2018
  • September 2018
  • August 2018
  • June 2018
  • April 2018
  • March 2018
  • January 2018
  • November 2017
  • October 2017
  • September 2017
  • May 2017
  • April 2017
  • December 2016
  • November 2016
  • August 2016
Wisconsin Bankers Association logo
  • About
  • Community
  • Subsidiaries
  • Staff

questions@wisbank.com

608-441-1200

4721 S Biltmore Ln.
Madison, WI 53718

Get our Newsletter!
Subscribe

© 2025 Wisconsin Bankers Association. All rights reserved. | Website Design by Bizzy Bizzy
Link to: My Unconventional Journey into Banking Link to: My Unconventional Journey into Banking My Unconventional Journey into Banking Link to: November/December 2023 Wisconsin Banker Link to: November/December 2023 Wisconsin Banker November/December 2023 Wisconsin Banker
Scroll to top Scroll to top Scroll to top

This site uses cookies. By continuing to browse the site, you are agreeing to our use of cookies.

OKLearn more×

Cookie and Privacy Settings



How we use cookies

We may request cookies to be set on your device. We use cookies to let us know when you visit our websites, how you interact with us, to enrich your user experience, and to customize your relationship with our website.

Click on the different category headings to find out more. You can also change some of your preferences. Note that blocking some types of cookies may impact your experience on our websites and the services we are able to offer.

Essential Website Cookies

These cookies are strictly necessary to provide you with services available through our website and to use some of its features.

Because these cookies are strictly necessary to deliver the website, refusing them will have impact how our site functions. You always can block or delete cookies by changing your browser settings and force blocking all cookies on this website. But this will always prompt you to accept/refuse cookies when revisiting our site.

We fully respect if you want to refuse cookies but to avoid asking you again and again kindly allow us to store a cookie for that. You are free to opt out any time or opt in for other cookies to get a better experience. If you refuse cookies we will remove all set cookies in our domain.

We provide you with a list of stored cookies on your computer in our domain so you can check what we stored. Due to security reasons we are not able to show or modify cookies from other domains. You can check these in your browser security settings.

Other external services

We also use different external services like Google Webfonts, Google Maps, and external Video providers. Since these providers may collect personal data like your IP address we allow you to block them here. Please be aware that this might heavily reduce the functionality and appearance of our site. Changes will take effect once you reload the page.

Google Webfont Settings:

Google Map Settings:

Google reCaptcha Settings:

Vimeo and Youtube video embeds:

Privacy Policy

You can read about our cookies and privacy settings in detail on our Privacy Policy Page.

Terms of Use
Accept settingsHide notification only

Subscribe

* indicates required








Membership