Some Comments on Comments

WBA submitted 13 comment letters to various federal regulators in the first seven months of this year. But why? That seems like a lot of time and effort for the legal department. The answer is actually pretty simple: because comment letters matter. 

The federal rulemaking process, as governed by the Administrative Procedure Act, requires agencies to give notice of any proposed rule that they intend to enact. The proposal must allow for interested parties to submit comments on the proposed rule that are then taken into consideration. Upon conducting a comment analysis, agencies then must decide whether to proceed with the rulemaking process or issue a new or modified proposal. In some cases, they will even withdraw the proposal. 

The comment period on these proposed rules is an important democratizing process. It’s an opportunity for those who are going to be impacted by a rule to tell agencies how it would impact them and make suggestions. That is why WBA submits comments on your behalf; we want to make sure that your regulators are acutely aware of how their rules will affect banking in Wisconsin. We make a point to comment consistently on large rulemakings, both on ones we are for and those we are against. 

WBA is dedicated to advocating for the banking industry in all facets. While submitting comment letters may not seem as cool as meeting with legislators and testifying before committees, it has a large impact on the rules governing the day-to-day operations of your banks. Because of that, we love to hear from you on proposed rules! If you have any thoughts on a proposed rule or are interested in writing your own comment letter, email us at wbalegal@wisbank.com to let us know what you think. Having input from you helps us craft a better comment letter. 

Those 13 comment letters we submitted from the beginning of January through the end of July are 13 points of contact that regulatory agencies had with Wisconsin’s banks. That’s 13 times they received and considered your concerns, and we’ll make sure they hear your concerns many more times.

By, Ally Bates