Tag Archive for: Advocacy

Posts

, , ,

Executive Letter: Advocacy in Action

From the Desk of Rose Oswald PoelsBy Rose Oswald Poels

WBA staff and 22 Wisconsin bankers joined more than 1,400 bankers from around the country last week for Congressional Hill visits on banking industry matters as part of ABA’s Washington Summit. WBA Board Chair Al Araque and I are very excited by the increased number of Wisconsin bankers who joined us on this trip, as well as those who already signed up for WBA’s second Washington Trip next month in conjunction with ICBA’s Capital Summit. We are grateful that you have responded to our requests to increase your personal involvement in these critical advocacy initiatives, and we are very pleased with the many bankers who joined us for the first time.

The timing of our Hill visits last Tuesday was fortuitous, as the House was taking a floor vote the next day on a key issue we supported: H.J. Res. 59, a congressional resolution of disapproval that would nullify the CFPB’s overdraft rule. The passage of this resolution means that CFPB is never able to introduce a similar rule again. While the vote in the House ultimately was along party lines, we were able to highlight in meetings with every Wisconsin congressional office the benefits consumers received from overdraft programs, along with the consequences of capping such fees.

Tax policy is top of mind in Washington, D.C., which gave us the opportunity to discuss with some of our delegation the importance of continuing the tax provisions that will expire at the end of 2025 — notably, the Section 199A pass-through deduction. We also focused on the ACRE Act, which would help deliver savings to farmers and ranchers across the country by providing a tax break to banks when making certain ag loans secured by farm real estate and aquaculture facilities, and for certain home mortgage loans. Currently, Reps. Steil, Fitzgerald, and Van Orden are co-sponsors of the ACRE Act, and we asked the other representatives to become co-sponsors as well. Other topics we advocated for included legislation that would repeal or narrow the scope of Section 1071, stablecoin legislation, and trigger leads legislation.

The Wisconsin bankers who joined Daryll Lund and me on this trip found it to be very educational and productive. Without question, WBA is more impactful when constituent bankers help deliver messages to elected officials. I encourage all of you to consider joining WBA next month for our second Washington Trip, May 12–15, 2025; later in the year when we meet with regulators (not legislators), October 16–17, 2025; or make plans now to join us next spring.

Thank you to the bankers who attended the WBA/ABA Washington Summit!
•  Al Araque, Johnson Financial Group, Racine
•  Tom Bloomer, State Bank of Chilton
•  Glen Calnin, State Bank of Chilton
•  Bill Dyson, Ladysmith Federal Savings & Loan Association
•  Morgan Farmer, Park Bank, Holmen
•  Dave Feldhaus, Federal Home Loan Bank of Chicago
•  Kristen Gagliano, North Shore Bank, Brookfield
•  Laura Hoerth, State Bank of Chilton
•  Damian Hoerth, State Bank of Chilton
•  Paul Hoffmann, Lake Ridge Bank, Middleton
•  Shay Horton, Cumberland Federal Bank, FSB
•  Corey Hoze, Associated Bank, Milwaukee
•  James Meisser, Lake Shore III Corporation, Glenwood City
•  Jeanene Meisser, Lake Shore III Corporation, Glenwood City
•  Morgan Mielke, Premier Community Bank, Green Bay
•  Tisha O’Dell, North Shore Bank, Appleton
•  Greg Ogren, Security Bank Shares, Iron River
•  Christine Ogren, Security Bank Shares, Iron River
•  Mark Oldenberg, Security Financial Bank, Eau Claire
•  Tom Pamperin, Premier Community Bank, Marion
•  Robert Traylor, Horicon Bank
•  Theresa Wiese, First Business Bank, Madison
•  Sarah Ziemba, American National Bank Fox Cities

/by
,

Advocacy Update: WBA Pushes Back on Swipe Fees Proposal and Forward with Legislative Priorities in 2025–26

By Lorenzo Cruz

The Wisconsin Legislature is back in session. One legislative issue which has resurfaced is credit card swipe fees. The draft proposal prohibits a financial institution from charging an interchange fee on the sales tax portion of a credit card transaction. The draft also includes the repeal of the Unfair Sales Act and could include data privacy language. A large retailers’ coalition is pushing the draft that WBA opposes. In 2021, the interchange bill died in committee.

What has sparked interest in moving legislation forward here in Wisconsin? Our Illinois neighbor passed a new interchange law last summer, which is being litigated in federal court. The Interchange Prohibition Fee Act prohibits charging or receiving the interchange fee on the portion of the transaction that covers state or local taxes and gratuities. Over a dozen differing interchange bills could be introduced nationwide in 2025.

Moreover, WBA’s Government Relations team continues to monitor and lobby legislators on the Association’s other priorities below for the 2025–26 legislative session.
•  Environmental, Social, and Governance (ESG) – WBA intends to minimize the impact of legislation that would prevent or limit a bank’s ability to make their own risk-based business decisions over loans and investments.
•  Trust Code – WBA continues to work with the State Bar on Domestic Asset Preservation Trust and other trust related changes.
•  Privacy – WBA continues to protect GLBA exemption for financial institutions and their affiliates in data privacy legislation.
•  Tax Parity – As more tax-exempt competitors leverage their competitive advantage over banks, WBA keeps pursuing legislative parity for the banking industry and its customers.
•  Artificial Intelligence – As artificial intelligence emerges as an issue nationally; WBA will collaborate with legislators to minimize the impact of any AI legislation on the banking industry.
•  Elder Fraud Prevention – While positive progress was made on a trusted list last session, obtaining the opportunity for a pause remains a priority for WBA during the 2025–26 session.
•  Merchant Category Codes – WBA will continue to neutralize any harmful legislation.

Switching gears to political fundraising, the GR team successfully raised over $271,000 in PAC and conduit contributions in 2024 and reached 90% of WBA’s year-end goal of $300,000, which set a record high. The team also delivered increases across the board in members for Leadership Circle, Silver Triangle, Gold Triangle, and Bankers Involved with Grassroots and Government (BIGG). WBA honored the recipients at a dinner during WBA’s Bank Executives Conference last month in Milwaukee.

Without the membership’s political advocacy support, WBA would not have been able to pass laws on an income tax exemption for banks on commercial/ag loans, banking modernization, trust code update, or elder fraud protections in the 2023–24 legislative session. Let us continue to amplify WBA’s advocacy impact by building on past legislative victories and setting new records for 2025 in political giving and attendance levels at Capitol Day on May 6, the Kohler issue advocacy outing on June 16–17, and the Milford Hills sporting clays PAC event on October 23. Thanks to all the members for their continued commitment to the cause that allows the Association’s unified voice to be heard above the rest.

Cruz is WBA vice president – government relations.

/by
,

Executive Letter: Your Voice Matters — Join Us in Washington, D.C. and at WBA’s Capitol Day This Spring

From the Desk of Rose Oswald PoelsBy Rose Oswald Poels

With a new administration in Washington, this is a pivotal time for grassroots advocacy — and your engagement has never been more important. Decisions made in the months ahead will shape the regulatory and legislative landscape for years to come. That’s why I strongly encourage you to join WBA’s upcoming advocacy events to ensure policymakers hear directly from the bankers who serve their communities every day.

Bankers from across the state are invited to join the WBA for two WBA Washington Trips to meet with our congressional delegation — one in conjunction with the American Bankers Association (ABA) Washington Summit and the other in conjunction with the Independent Community Bankers of America (ICBA) Capital Summit.

• WBA/ABA Washington Summit April 7–9, 2025
• WBA/ICBA Capital Summit May 12–15, 2025

Both summits provide an exclusive opportunity to meet with our congressional delegation during visits to Capitol Hill that are arranged for you by WBA staff, share the challenges facing your financial institution, and help influence key policy decisions.

No matter your bank’s membership in either national trade group, all WBA members are welcome to join either trip. There is no registration fee, though attendees are responsible for travel and accommodations.

If traveling to D.C. isn’t feasible this spring, I urge you to participate in WBA’s Capitol Day in Madison on May 6, 2025. This one-day event is a powerful way to engage with state lawmakers and advocate for the strength and stability of our industry right here at home.

Grassroots advocacy is the foundation of our success. Your voice carries weight, and when bankers unite, we make a lasting impact. Let’s work together to ensure our industry’s concerns are understood and addressed at every level of government.

Please contact me at ropoels@wisbank.com, Daryll Lund at dlund@wisbank.com, or Lorenzo Cruz at lcruz@wisbank.com with questions or to confirm your attendance.

Click here to download a flyer to share with your team.

 

 

/by

Advocacy Update: Engage, Advocate, Lead: A Call to Action for Wisconsin’s Banking Industry

By Lorenzo Cruz

The fall elections are finally done and so is the onslaught of non-stop political TV ads. Enjoying the momentary reprieve from ads, we can expect to see another heavy barrage of political advertisements during the spring election for ideological control of the state supreme court.

There was a red wave that hit Wisconsin, but the state remains purple with a divided government. As predicted, the Legislature remains in the hands of the GOP under the new maps but with smaller majorities. The Assembly now has a 54-45 majority, and the Senate stands at an 18-15 majority with the East wing held by Democratic Governor Tony Evers.

At the federal level, President-elect Donald Trump and incumbent U.S. Senator Tammy Baldwin (D-WI) defeated their respective opponents, Vice President Kamala Harris for the presidency, and businessperson Eric Hovde for Senate by less than one percent. There were no surprises in the competitive U.S. Representatives races. Steil, Van Orden, and newcomer Wied replacing Gallagher won by sizable margins.

2025 marks the beginning of a new legislative session. We have 37 fresh faces to work with at the state capitol, six from the Senate and 31 in the Assembly. The caucuses in both chambers reelected their leaders: Assembly Speaker Vos, Assembly Minority Leader Neubauer, Senate Majority Leader LeMahieu, and Senate Minority Leader Hesselbein. Committee chairs and members will begin their legislative work after inauguration day in early January. The Governor’s State of the State address is set to occur later in the month.

Legislators will primarily focus on passing a version of the Governor’s state budget before July 4. With a reported $4 billion surplus, the debate will center on tax cuts, spending, education, health care, transportation, environment, and corrections. Meanwhile, there will be bills that legislators introduce and move through the legislative process which the WBA Government Relations team will be monitoring.

WBA’s team has been communicating with new and key legislators on WBA’s legislative priorities: interchange fees, taxes, ESG, Trust Code, credit unions, and artificial intelligence. Other policy issues revolve around banking modernization, privacy, merchant category codes, elder fraud, and SWIB investment risk.

As the WBA GR Team continues its advocacy efforts, I encourage bankers to remain engaged in political advocacy. WBA’s Advocacy Toolkits will go out in February, and I urge bank presidents/CEOs to work with their advocacy officer to launch their political fundraising campaign for the PAC and conduit early in the year to achieve Gold Triangle recognition for banks and Leadership Circle and Silver Triangle recognition for individual bankers. Other political fundraising events I ask bank leaders to get involved with are the issue advocacy event June 16–17 at Kohler and the PAC sporting clays event at Milford Hills on October 23.

On the grassroots side of advocacy, I urge all banks to send their Advocacy Officers and other employees to WBA’s Capitol Day on May 6 in Madison. It is a fantastic way for bankers to function as one unified voice and effectively lobby legislators and staff on banking issues impacting their communities back in their districts. Thank you all for supporting WBA’s advocacy efforts.

Cruz is WBA vice president – government relations.

/by
,

Executive Letter: Advocacy Win: FCC Allows Banks to Issue LOCs to Recipients of High-Cost Support Awards

By Rose Oswald Poels

In actions which first began back in February, WBA lead industry efforts to convince the Federal Communications Commission (FCC) of the need to revise rules which required banks to obtain a Weiss bank safety rating of B- or better in order to be eligible to provide a letter of credit (LOC) to recipients of FCC’s Rural Digital Opportunity Fund.

In those efforts, I am extremely proud to have been able to partner with other state banking associations to become engaged in these efforts and of the success in August of having 75 State Banking Associations join with WBA to file a coalition letter asking for FCC to revise their rules and eliminate the requirement for banks to maintain a Weiss bank safety rating of B- or better.

I am excited to report that in actions taken last week, FCC announced the elimination of the use of the Weiss bank safety rating as the standard for banks to be considered “acceptable to FCC” for the purpose of issuing qualifying program LOCs. FCC revised their rules to make a bank “acceptable to FCC” if it is a United States bank insured by FDIC that meets the criteria to be considered “well capitalized” as determined by FDIC, FRB, or OCC.

When future LOCs are submitted by FCC program recipients to demonstrate compliance with FCC rules, FCC will require a certification from a United States bank’s officer that the bank meets the criteria to be considered well capitalized by FDIC, FRB, or OCC. FCC will confirm the bank’s status on publicly-available metrics.

In addition, FCC did not expand the program to allow credit unions to participate as being “acceptable to FCC” under the program rules. FCC received this request during the open comment period of their rule revision process.

Often, results on the advocacy front can take a long time. However, thanks to the efforts of several WBA members who shared their insights with me regarding the matter earlier this year, WBA’s repeated advocacy, as well as broad industry advocacy, the FCC staff conducted a thoughtful and thorough review of their rules’ requirements and of the impacts of using an unreliable bank safety rating tool on the mission of their programs and on rural communities. Thanks to the actions by FCC, rural communities will continue to have the support of eligible telecommunications carriers and banks can continue to support their local carriers and communities while still protecting the integrity of FCC’s programs.

/by
,

Executive Letter: Upcoming Opportunities to Meet Regulators in Madison

By Rose Oswald Poels

WBA’s advocacy efforts take on many forms, including the opportunity for banks to host a “Take Your Legislator to Work Day”, participate in trips to Washington, D.C. to meet with decision makers of banking issues, and through the efforts of the WBA Government Relations team to advance pro-banking legislation.

Advocacy efforts can also take affect through meeting with state and federal regulators. In addition to traveling to Washington, D.C. for WBA’s Fall Regulatory Trip, I have hosted many meetings over the years with bankers and state and federal banking regulators at the WBA Offices. These meetings allow for senior bank management to meet directly with regional or local regulators for small group discussions. These meetings have always led to meaningful conversations and allow bankers the opportunity to share concerns directly with their regulators.

As with many things during the pandemic, our local regulatory meetings had been postponed given travel restrictions of the supervisory agencies and so that bank management could focus on assisting customers and staff through pandemic recovery. However, time has now come to reinvigorate these meetings and to once again host an opportunity for bankers to meet with regulators here in Wisconsin.

Over the next several months I will be working to arrange in-person meetings with the FDIC, OCC, FRB, and DFI at the WBA Offices in Madison. These meetings are with regional and local office representatives and are limited in size to allow for all participants to engage directly with supervisory staff. Dates have not yet been set for the upcoming meetings; however, we are collecting names of those seeking to participate in the small group meetings.

If you wish to participate in an upcoming small group meeting with your federal or state regulator, please share your name and contact information with WBA’s VP Legal, Heather MacKinnon, at 608-441-1263 or hmackinnon@wisbank.com. As we work to finalize meeting arrangements, we will reach out with each of you directly regarding available meeting dates/times and to finalize meeting plans.

Please consider this opportunity to meaningfully impact WBA’s regulatory advocacy and join a small group meeting with your banking regulators here at the WBA Offices. Space is limited to 8-10 bankers per meeting.

/by
, ,

Executive Letter: A Commitment to Investing in the Future Prosperity of Our Industry

By Rose Oswald Poels

Even though votes are still being counted in several uncalled U.S. House of Representatives races as of this morning, Republicans have now reached 218 seats in the House of Representatives so will have full control (with narrow margins) of the federal government with the trifecta of the White House, Senate, and House of Representatives.

Regardless of your party affiliation, without the non-stop barrage of election-related texts, calls, emails, and political ads, we can now move forward with clarity and a continued commitment to advocate for the industry with one voice to promote a healthy environment that allows your bank, customers, and your communities to prosper. WBA’s government relations team remains dedicated to continuing to work with legislators on both sides of the aisle.

This past biennium, WBA, working alongside many engaged bankers, achieved numerous positive bi-partisan legislative results for the industry. WBA will continue its impact in the new biennium, focusing on the legislative priorities established by our Government Relations Committee and Board of Directors.

The industry’s active political involvement is also critical to ensure our voice is heard. I want to thank many of you who have already personally contributed to WBA’s political action committee or conduit account this year; however, we still need more contributions to reach our goal.

So far, WBA has raised 80% of our $300,000 goal for 2024. With less than 50 days left in the year, we need your help now to achieve this critical investment in the industry’s advocacy future. I know that the economy remains challenging and that asking your management team and board for personal contributions for political purposes can be difficult; however, without meaningful political contributions, WBA is limited in our abilities to succeed on your behalf.

Every year, I personally contribute between $4,000 and $5,000 to WBA’s political accounts because it is crucial to me to support the industry that has given me so much opportunity during my career. I encourage you to consider giving at least $1,000 which qualifies you for the Silver Triangle Club, or $3,000 or more which qualifies you for the Leadership Circle.

Currently there are 13 Leadership Circle members, 89 Silver Triangle members, 36 Gold Triangle members, and 37 BIGG Award Recipients.

Thank you to so many of you who have engaged in our grassroots calls-to-action throughout this year, by contributing to our political funds, joining us in Madison for Capitol Day (save the date: May 6, 2025) or in Washington, D.C. during our annual advocacy trips. This year the inaugural Milford Hills Outing, a sporting clays event, was held in October and will likely grow in popularity and impact. Without your engagement, we truly are not as effective as we need to be to achieve our priorities. Direct involvement from bankers is critical to helping the WBA advocacy team achieve success for the banking industry. It is our goal to provide bankers like you with a seat at the table to positively shape and influence legislation and rules impacting the industry.

To learn more about WBA’s advocacy efforts and to contribute to one or both of our political accounts, please visit wisbank.com/advocacy. If you would like to schedule an advocacy presentation for your bank, please contact a member of our Government Relations team. If there is someone on your team who would be interested in an Advocacy Officer role, please encourage their participation.

/by
,

Advocacy Update: Strengthening Our Industry Through Grassroots Advocacy and Financial Giving

By Lorenzo Cruz

Members of the Wisconsin Bankers Association are at a critical point in our industry. Amid the backdrop of the fall elections, the financial landscape is rapidly changing with new regulations, technological advancements, and economic challenges that impact our day-to day operations. Now more than ever, it is crucial that bankers not only stay informed, but also actively participate in the shaping of our industry’s future.

The Power of Grassroots Advocacy
Grassroots is the cornerstone of our efforts to influence legislation and regulatory decisions that affect our industry. By engaging with policymakers at all levels of government, we can ensure that our voices are heard, and that the unique viewpoints of our industry are considered.

But advocacy is not just about lobbying or talking with elected officials. It is about building relationships and educating them on the real-world effects of their decisions. When we work together as a community to advocate for reasonable regulation and policies that promote growth, we empower ourselves to create a stronger, more resilient financial sector.

Why Your Involvement Matters
Each one of us has a role to play in this process. Whether you are managing a small community bank or leading a large institution, your perspectives and experiences are invaluable. Policymakers need to hear from those who are on the front lines, collaborating directly with customers and understanding the complexity of financial services.

Your involvement in grassroots advocacy can take many forms:
•   Contacting your elected officials is one way. Share your experiences and concerns via email or a phone call and educate them on the impact of proposed legislation on business and customers.
•   A second way is to attend public hearings. Show up where decisions are being determined and express your opinions by providing testimony or registering a position.
•   Participating in Capitol Days and federal delegation trips is another approach. Join bankers in organized visits to policymakers to collectively advocate for the legislative priorities that matter most to our industry.

Supporting WBA’s Fundraising
In addition to your personal engagement, financial donations to WBA’s Political Action Committee (PAC) and conduit account are vital. These funds allow our association to support candidates who understand and prioritize the banking industry’s concerns. By combining our resources, we can ensure that our industry’s voice is heard in the hallways of the capitol.

Why your contribution matters:
•   It amplifies our influence. Financial contributions enable us to support lawmakers who align with our industry’s goals, ensuring they have the resources to campaign effectively.
•   It protects our interests. By contributing to PACs and conduit accounts, you help safeguard our industry from potentially damaging legislation.
•   It promotes informed decision making. With strong financial support, we can continue to provide valuable information to policymakers, helping them make decisions based on solid data and industry expertise.

A Call to Action
We urge every WBA member to get more involved in overall grassroots advocacy (BIGG) and financial giving at the individual level (Leadership Circle or Silver Triangle) and at the bank level (Gold Triangle). Act now to help us meet our 2024 fundraising goal of $300,000 by contributing securely online via credit card at wisbank.com/advocacy or mailing a check payable to Wisbankpac or to Alliance of Bankers for Wisconsin to WBA.

Whether it is donating financially, reaching out to a legislator, or participating in an advocacy event, every effort counts. Together, we can ensure that the banking industry remains a vital, vibrant part of our economy. Your voice, your engagement, and your contributions make all the difference. Let us commit to being proactive advocates for our industry, today and in the future.

Thank you for your continued commitment to the success of our association and the banking industry.

Cruz is WBA vice president – government relations.

/by
,

Chair’s Column: Amplifying the Impact of Advocacy

By Al Araque

I recently met with WBA President and CEO Rose Oswald Poels, WBA Vice President – Government Relations (GR) Lorenzo Cruz and my fellow Officers to discuss legislative priorities for the Association and how Board members like me and senior management/leadership at member banks can get more engaged in advocacy. That critical need for engagement and participation extends beyond C-suite leaders to employees at every phase in their careers.

The more I see WBA’s Government Relations team, which also includes Executive Vice President and Chief of Staff Daryll Lund and Director – Government Relations Tyler Foti, in action it becomes clear that the staff/member dynamic is truly symbiotic in nature. As a member, I rely on the insights and expertise of WBA’s seasoned GR professionals as they represent banks in Wisconsin, but they in turn rely on the grassroots efforts, financial contributions, and valuable perspectives from WBA members. Without the engagement of members, there is only so much that our GR pros can do. Legislators need to hear from you and candidates need to know that WBA has the financial support of its members.

As I shared in my introductory column this summer, my focus is on amplifying the impact of WBA, and there are many ways that WBA’s advocacy work can be amplified.

Generosity in Sharing Stories from the Frontline to the Board Room
You have your finger on the pulse of what is happening in your community and can speak convincingly to legislators about the public policy issues impacting your customers, employees, and local economy. Providing testimony, whether it is in person at hearings or written, can help legislators get clarity on a complex industry-related issue.

Attending Capitol Day on May 6, 2025: Attendance at this annual event is incredibly important. If you have never been before, make 2025 the year that you connect directly with legislators and network with other bankers. Members are briefed on the issues and guided through the legislative visits. The larger the group, the more impactful the Association is. I’ve heard that Capitol Day can often be a tipping point for members who end up becoming really engaged and interested in advocacy after witnessing the combined impact of WBA members.

Having a WBA Advocacy Officer from your bank: This volunteer position coordinates regulatory, legislative, and community advocacy efforts for your bank by teaming up with WBA. Advocacy Officers often work with other banks, WBA staff, legislators, and community leaders. The time commitment
is low, especially when considering the impact officers make.

I realize not everyone is immediately comfortable with these kinds of grassroots activities. It may seem daunting initially, but I know that GR staff is always willing to share talking points, bring members up to speed on the issues, and facilitate communications with legislators. The goal of the GR staff is to make your grassroots involvement easy!

Generosity with Financial Contributions
Not everyone has a clear picture of how to support WBA’s political initiatives.

Wispankpac is the registered political action committee of the WBA and supports pro-banking candidates throughout Wisconsin by pooling individual banker contributions to maximize their overall impact in the political process.

Alliance of Bankers for Wisconsin (ABW) is the registered conduit of the WBA and allows an individual banker (like you) to direct contributions to the candidate(s) of your choosing and receive individual credit for your contribution.

Finally, WBA also works with other business coalition partners on issue advocacy initiatives. Corporate contributions to WBA for issue advocacy purposes are permitted under the law.

So, the amplification of WBA’s influence can come from individuals as well as banks. WBA also has several programs to acknowledge the generosity of individuals and banks.
•   Silver Triangle Club recognition is given to individuals who personally donate at least $1000 to ABW, Wisbankpac, and/or the WBA issue advocacy fund. For Leadership Circle recognition, individual bankers must contribute at least $3,000 to any combination of Wisbankpac or the ABW conduit.
•   Gold Triangle recognition is achieved by banks whose officers, directors, and employees aggregately contribute a minimum amount to the ABW political conduit or Wisbankpac. Banks may also make corporate contributions to WBA’s issue advocacy fund.
•   The BIGG (Bankers Involved with Grassroots and Government) Award is the Association’s highest level of recognition for advocacy by our member banks. To receive this award, banks must complete five out of seven criteria described in WBA’s Advocacy Toolkit.

As the November 5 election approaches and brings with it some polarizing viewpoints, I’m reminded of a quote from Rose that I think can be helpful when you talk to staff about the need for grassroots advocacy and contributions, “Funds raised by WBA are used to help support pro-banking political candidates who are not ‘D’ or ‘R’, but rather ‘B’ for the ‘Banking’ Party.” Speaking of the election, WBA has partnered with ABA for a Get out the Vote initiative, which has lots of useful information to share with staff.

Araque is SVP, director of consumer, private, and business banking with Johnson Financial Group, Racine, and the 2024–2025 WBA Chair.

 

/by
,

Executive Letter: WBA’s Regulatory Advocacy Through Comment Letters

By Rose Oswald Poels

One of WBA’s primary roles is to advocate for the banking industry. Much of the focus of staff and bankers is on our collective legislative advocacy. In addition to legislative advocacy, WBA also works hard to advocate for the industry through our involvement in court cases by filing an amicus curiae brief, and through our comment letter writing and meetings with regulators. Given the number of regulations the banking industry must manage, regulatory advocacy is critical. In the last few months, WBA has been busy on that front on several key issues affecting the industry.

Comment letters are an excellent mechanism for federal agencies to hear about the impact their regulations have on the banking industry. WBA’s legal team has been busy ensuring that federal banking regulators understand the impact their proposed rules have on Wisconsin’s banks. One of the recent comment letters filed by WBA was with the Consumer Financial Protection Bureau (CFPB), responding to CFPB’s request for information regarding fees imposed in residential mortgage transactions. CFPB’s request arose in response to recent studies, and claims that “junk fees” are driving up housing costs.

In our comment letter, WBA expressed concerns with CFPB’s characterization of mortgage fees and commented that CFPB should not inappropriately prejudge and inaccurately categorize legitimate and necessary fees as junk fees. WBA emphasized that Wisconsin banks don’t add fees to loan costs other than necessary fees and provided numerous and specific examples of loan costs.

WBA also filed comments on CFPB’s interim final rule to extend the compliance dates for its 2023 small business lending rule (1071 rule). The interim final rule extends the 1071 compliance dates 290 days to compensate for the period that was stayed by court order (July 31, 2023 to May 16, 2024). WBA expressed that we still hold significant concerns regarding the scope and negative impact of the 1071 rule but appreciate CFPB’s prompt issuance of clear time periods clarifying the new compliance dates.

WBA also encourages bankers to get involved in our regulatory advocacy work through writing comment letters or attending meetings with regulators. Every October, I take a small group of bankers with me to Washington, D.C. for the purpose of meeting with federal banking regulators. The dates this year are October 21–22, 2024. While we are still in the process of scheduling the meetings, I am hoping to meet with senior officials from the FDIC, Federal Reserve, OCC, CFPB, FHFA, and SBA. If you are interested in joining me on this year’s trip, or would like to learn more, please contact me at your earliest convenience as I limit our group size to around 12 bankers. As with our legislative and judicial advocacy, WBA will continue to fight for the industry through our ongoing active regulatory advocacy as well.

/by
Wisconsin Bankers Association logo

questions@wisbank.com

608-441-1200

4721 S Biltmore Ln.
Madison, WI 53718

Get our Newsletter!
Subscribe