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WBA’s Push to Uphold Fair, Balanced Regulation

From the Desk of Rose Oswald Poels

WBA remains committed to advocating for policies that preserve fairness across the financial system.

Last week, we joined the American Bankers Association (ABA) and state banking associations nationwide in signing a joint letter to the U.S. Treasury Department urging officials to uphold the GENIUS Act’s prohibition on interest payments to stablecoin holders.

We are seeing digital assets and stablecoins garner more and more national attention. This letter focused on a narrow but significant provision within Treasury’s Advance Notice of Proposed Rulemaking (ANPR). The correspondence specifically addressed Treasury’s inquiry into whether future regulations should define terms such as “pay,” “interest,” and “yield.” This question, if expanded too broadly, could erode the distinction between bank deposits and privately-issued digital tokens.

This letter reaffirms WBA’s commitment to safeguard the traditional banking model and maintain the trust that comes with regulated depository institutions.

WBA also recently submitted three formal comment letters on behalf of Wisconsin’s banking industry to federal agencies addressing important regulatory priorities:

  1. WBA Comments on FDIC Part 328 Signage Proposal

    WBA submitted comments supporting the FDIC’s proposed revisions to digital signage requirements under 12 CFR Part 328. The letter highlights ongoing implementation challenges with the 2023 final rule — particularly across varied digital platforms — and urges FDIC to align compliance timelines. WBA supports proposed changes including the removal of prescriptive design elements, narrowing of signage scope, and flexibility for mobile applications. The association also endorsed revisions to the one-time notification standard and expanded ATM signage exceptions, while recommending additional clarity on the “clear, continuous, and conspicuous” display standard and third-party platform obligations.

  2. WBA Comments on CFPB Section 1033 Reconsideration

    WBA also submitted comments supporting the CFPB’s decision to revisit the Personal Financial Data Rights rule under Section 1033 of the Dodd-Frank Act. The letter urges CFPB to suspend compliance dates from the 2024 final rule and recommends narrowing the definition of “representative” to fiduciaries only. WBA further supports allowing reasonable fees for data access and prohibiting screen scraping due to security risks. Additional recommendations call for a clear liability framework, consistent standards across all covered entities — including fintechs — and limiting the scope of data to products already obtained by the consumer. WBA also advocates for express consent requirements, reliance on industry-led standards like FDX, and a minimum two-year compliance timeline following standard adoption.

  3. WBA Comments on GENIUS Act Implementation

    In addition to the joint letter mentioned above, WBA separately submitted comments in response to Treasury’s Advance Notice of Proposed Rulemaking regarding the GENIUS Act. The letter emphasized the need for a balanced regulatory framework that supports innovation in stablecoins while safeguarding consumers and financial stability. WBA highlighted concerns about regulatory spillover into traditional banking, especially regarding BSA/AML compliance burdens. The letter urged Treasury to avoid compounding existing obligations and to consider operational challenges.

    Additional recommendations included prioritizing consumer education, ensuring competitive equity across financial entities, and supporting rural inclusion through targeted investments and partnerships. WBA also called for clear guidance to help banks manage emerging risks related to fraud, cybersecurity, and liquidity.

WBA’s recent advocacy work seeks to ensure that policymakers fully understand the role of Wisconsin’s banks as trusted, community-focused financial partners. Thank you to the many bankers across the state who continue to engage with WBA’s advocacy efforts — whether through grassroots outreach or direct conversations with lawmakers. Your voice matters!

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Executive Letter: Celebrating Achievement in Wisconsin Banking

From the Desk of Rose Oswald Poels

The Wisconsin Bankers Association takes great pride in honoring the committed professionals who dedicate their career to preserving the integrity of our industry and promoting financial literacy in our communities. The awards listed below serve to recognize individual excellence and inspire the industry to strive for greatness.

This season offers many opportunities to honor those who are making a difference across our state. I encourage you all to take a few minutes to submit a nomination for the following awards now open:

  1. WBA Banker of the Year Award (due December 5): This award recognizes a bank president or CEO (or an individual who has recently retired from these positions) who has made an outstanding effort in service to his or her community and to the banking profession. The award will be presented at the WBA Bank Executives Conference on February 4–6 in Wisconsin Dells.

  2. WBA 50- and 60-Year Club (due December 5): This award recognizes bankers who have served in the banking industry for 50–59 and 60+ years respectively. These awards will be presented at the WBA Bank Executives Conference on February 4–6 in Wisconsin Dells.

  3. WBA Lifetime Service Award (rolling deadline): The 30-Year and 40-Year Lifetime Service Award recognizes active and retired employees who have completed 30–39 or 40–49 years in the banking industry. Awards are presented by me or a WBA senior management team member at the honoree’s bank.

  4. Governor’s Financial Literacy Award (due November 21): Sponsored by the Wisconsin Department of Financial Institutions and the Governor’s Council on Financial Literacy and Capability, this award recognizes individuals and organizations for increasing financial literacy, capability, and inclusion among Wisconsin residents.

WBA believes that strong banks depend on smart, passionate, and principled people. Please help us recognize exemplary leaders and colleagues in your organization who embody these values in their work.

Thank you for taking the time to recognize excellence in our profession! Your contributions ensure the achievements of our peers are remembered for years to come.

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Executive Letter: Join the Industry Effort to Modernize BSA/AML Thresholds by Friday, October 31

From the Desk of Rose Oswald PoelsBy Rose Oswald Poels

WBA is joining our peers across New England and beyond in calling for long-overdue updates to the Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) regulations. We invite your institution to add its name to a joint letter to Treasury Secretary Bessent urging that the thresholds for Currency Transaction Reports (CTR) and Suspicious Activity Reports (SAR) be raised to $50,000.

These thresholds have not been adjusted in decades. Raising them will allow law enforcement to focus resources on the most significant criminal activity while reducing unnecessary reporting burdens on banks.

We discussed this important issue on our regulatory trip to Washington, D.C. last week with policymakers. Several other states — including New Hampshire, Connecticut, Rhode Island, Vermont, and Massachusetts — are already circulating this letter as part of a growing regional and national effort.

The attached letter outlines the request in full and will be sent to Treasury Secretary Bessent with the names of participating banks included as signatories. There is no need to draft a separate response — simply review the letter, and if your institution does not wish to be listed, please contact wbalegal@wisbank.com by the end of the day Friday, October 31 to opt out.

Modernizing these reporting thresholds represents a pivotal opportunity to enhance efficiency and reduce operational strain on community banks. Please contact wbalegal@wisbank.com with any questions. Thank you for taking part in advocacy that strengthens our industry.

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Executive Letter: Advocacy in Action: Meeting with Regulatory Leadership

From the Desk of Rose Oswald PoelsBy Rose Oswald Poels

Last week, nine bankers joined WBA’s Heather MacKinnon, VP – Legal and Communications and I in Washington, D.C. for our annual trip to meet with federal regulators. The small group format once again proved productive and resulted in impactful advocacy and conversations. In the span of only two half-days, the group met with senior officials from the FDIC, OCC, and Federal Reserve, as well as CSBS and Congressman Bryan Steil. We discussed regulatory relief, tiered regulation, indexing for community banks, deposit insurance reform, payments fraud, community bank capital standards and mutual capital, modernization of Regulation O, preemption and protection of National Bank Act, and emerging issues such as the Debanking Executive Order, stablecoin, the GENIUS Act, and the Clarity Act.

Our conversation with FDIC Deputy to the Chairman of Policy Alex LaPore and Director of FDIC’s Division of Risk Management Supervision Ryan Billingsley focused on several issues noted above as well as WBA’s concern that there is an out-sized focus by examiners in Wisconsin enforcing the National Flood Insurance Act. We also stressed the need for the Community Bank Leverage Ratio to be revised before it is more widely adopted by community banks. While FDIC representatives noted the agency remains neutral on deposit insurance reform as legislation advances in Congress, bankers urged greater transparency in deposit insurance analysis and data. Finally, we also raised industry concerns regarding the shortening of hold periods under Regulation CC exemption rules, emphasizing that extended hold times are often necessary when fraud is suspected to allow banks sufficient time to verify check legitimacy.

The topics discussed during our conversation with OCC Assistant Deputy Comptroller Brent Acree, Senior Advisory for Thrift Supervision Charlotte Bahin, and Director of the Office of Financial Technology Dave Stankiewicz were similar to those with FDIC. We also discussed the importance of continuing its focus on preserving preemption for nationally chartered banks.

Finally, our conversation with FRB’s Aleksandra “Aleks” Wells, senior advisor to Fed Governor Michelle Bowman, also focused on the need for regulatory relief and for tiered regulation and indexing for community banks, in particular on adjustments to BSA/AML filing requirements and to Regulation O limitations. The group also suggested greater transparency in branch and bank merger applications and recommended an automatic approval process for branch applications by well-rated institutions.

Participate: Be an Advocate in Action!

Each year WBA has three Washington, D.C. fly-ins: two Hill-focused events in the Spring in conjunction with ABA and ICBA, and then a Wisconsin-only regulatory-focused trip in the Fall. As stated above, these meetings are impactful as bankers are able to meet directly with decision makers and influencers regarding banking issues. Changes in policy and greater issue awareness do occur as a result of these meetings, and I highly encourage you to consider attending either our Hill visits or next year’s regulatory trip!

I would like to thank the following bankers for joining WBA last week: David Feldhaus, Federal Home Loan Bank of Chicago; Corey Hoze, Associated Bank; Gary Kuter, Bank of Sun Prairie; Jeff Langkamp, Bank Five Nine; Kat Detloff, Ladysmith Federal Savings and Loan; Kristen Gagliano, North Shore Bank; Robin Christian, Premier Community Bank; Timothy Schneider, Bank Five Nine; and Todd Nagel, IncredibleBank. If you are interested in joining WBA on this trip next October, please let me know!

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Executive Letter: Grassroots Needed on Digital Assets Legislation

From the Desk of Rose Oswald PoelsBy Rose Oswald Poels

WBA, ABA, ICBA, and other state banking associations worked hard to minimize the impact of the GENIUS Act as it moved through Congress earlier this year. We received assurances from elected officials that this stablecoin legislation was a “payments” bill, providing a framework and protections for stablecoins to be used as a form of payment in the United States. It was also clear that protecting the banking industry from any potential disintermediation remained a priority.

While the GENIUS Act language was not perfect, members of Congress indicated that any legislative “fixes” would be done through a separate market structure bill in the Senate. Since the passage of the GENIUS Act, WBA and other trade associations have expressed concern that loopholes within the law — if left unaddressed — could lead to deposits leaving the traditional banking system. Such a shift would ultimately harm local lending, as yield-bearing stablecoin issuers incentivize consumers to store their funds outside of banks. The unintended (or perhaps intended) consequences of stablecoins becoming more of a store of value instead of simply a form of payment are real and harmful for the banking system and the economy.

WBA urges all bankers to contact our U.S. Senators today to close the loopholes left open in the GENIUS Act in order to protect consumers, promote economic stability and preserve credit access. In particular, the ask to lawmakers is to:

  • Extend restrictions on paying interest or yield on payment stablecoins to cover all market participants. This will help ensure that payment stablecoins serve as a payment tool while minimizing unintended consequences for the banking system and broader economy.

  • Repeal section 16(d) of the GENIUS Act. This will protect consumers and competition by guaranteeing state banking authorities have the power to supervise out-of-state chartered uninsured depository institutions, leveling the playing field for all institutions operating within a state.

  • Prohibit non-financial companies from issuing stablecoins, restricting the ability for deposits to be siphoned from community banks and therefore preserving local community access, preventing conflicts of interest, and the concentration of economic power.

Both ABA and ICBA have action centers where you can easily and quickly send these letters now.

Please share this message with your entire staff! The Senate markup on this legislation is coming soon so it is imperative that they hear our message now. The “other side” has already generated tens of thousands of contacts supporting passage of this market structure bill without closing these critical loopholes. Now is the time for the banking industry to be just as loud.

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Executive Letter: Cybersecurity Awareness Starts with Education

From the Desk of Rose Oswald PoelsBy Rose Oswald Poels

October is Cybersecurity Awareness Month — an annual reminder that protecting our customers is an ongoing and ever-evolving effort.

Bankers continue to see a range of scams targeting both customers and financial institutions — and these scams are no longer confined to clumsily-written emails and suspicious links. Bad actors use a mix of increasingly sophisticated techniques that weaponize social engineering and artificial intelligence to make phishing attempts appear legitimate to even the most cautious customer. Wisconsin bankers are seeing a rise in tactics such as:

  • AI Impersonations: Scammers use AI-generated voices that sound friendly and familiar, or emails that convincingly mimic a trusted institution.

  • Spoofing: Bad actors disguise a phone number, email address, or website to appear as though it is coming from their community bank or a government agency.

  • Phishing: Criminals send emails or texts that trick recipients into revealing sensitive information or clicking malicious links.

  • Brushing Scams: Consumers receive unsolicited packages as a part of fake transactions designed to boost a seller’s online credibility or steal personal information.

  • Romance Scams or Catfishing: Bad actors build emotional connections with victims online using stolen photos to gain their trust, then manipulate them into sending money or sharing personal information.

  • Cryptocurrency Scams: Criminals pose as investment advisors or romantic partners to convince victims to transfer funds into digital wallets. These transactions are nearly impossible to reverse.

  • Gift Card Scams: Scammers pressure victims into purchasing gift cards as “payment” for supposed fees or emergencies. Once the numbers are shared, the funds are instantly drained and nearly untraceable.

  • Synthetic Identity Fraud: Fraudsters combine real and fake personal data to create entirely new identities to open fraudulent accounts or apply for loans.

Education remains our best defense. WBA offers a library of consumer-facing resources designed to help Wisconsin banks communicate types of fraud and prevention tips to customers. Our latest “Don’t Be Spoofed” piece, along with additional cybersecurity safety resources like “Building Your Online Security” and “Don’t Get Spooked by Scams” are available for download on our website. These materials are ready to share on your websites, or easy to print to share in-branch with your customers.

Cybersecurity Awareness Month is the perfect opportunity to review internal protocols with your staff, refresh training, and speak directly with your customers. After all: Trust is at the heart of a successful banking relationship.

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Executive Letter: WBA Guidance for Response to SBA Debanking Letter

From the Desk of Rose Oswald PoelsBy Rose Oswald Poels

As a follow-up to the complimentary live webinar hosted earlier this month with myself and Peter Wilder, attorney with Godfrey & Kahn, I requested Peter to prepare guidance for response to the SBA debanking letter we discussed in that webinar. The following is that prepared guidance.

In late August, the Small Business Administration issued a letter (Letter) to over 5,000 lenders in response to President Trump’s Executive Order 14331 called “Guaranteeing Fair Banking For All Americans”. The Letter directs lenders to identify and remediate instances of politicized or unlawful debanking actions by December 5, 2025, and also requires the submission of a detailed report to the SBA by January 5, 2026. The risks of noncompliance can be severe. In response to several inquiries, we have found that a general framework for a compliance process may be helpful for bank boards and management teams.

•  Internal Risk Assessment. The Letter is directed toward financial institutions “participating in the [SBA]’s loan guarantee programs”. We expect each bank to take a risk-based approach to the Letter’s directives based on its own unique circumstances. There is no “one size fits all” approach. For example, if a bank received the Letter but does not participate in the SBA’s loan guarantee programs, it may wish to limit its efforts to sending a reply letter to the SBA to that effect. If a bank received the Letter and engages in the SBA’s loan guarantee programs as part of its business, it will want to conduct a thorough, good-faith process to document its efforts to comply with the Letter’s directives and report any findings. The more heavily the bank relies on SBA loan programs for its business, the more robust its process and documentation should likely be.

•  Inform Your Board of Directors. Banks receiving the Letter will want to inform and educate their boards. The board should directly oversee compliance with the Letter.

•  Approve a Process. We expect boards to approve a process by which the bank will comply with the Letter. The process may include, for example: (a) appointment of a person (e.g. internal auditor or compliance officer) or a committee, who is responsible for investigating and reporting all findings to executive management and the board; (b) identification of all sources of information to be reviewed (e.g. loan policies, loan committee and board minutes, credit denials and adverse action notices, customer complaints, reports of examination, internal and external audit reports, and interviews with relevant department heads within the bank); (c) establishment of a “look-back” period of how far in the past the bank will investigate; (d) engagement of any outside professionals (e.g. accountant, lawyer, etc.); and (e) a timeline for completion.

•  Execute the Process. The individual or committee responsible for conducting the review should follow the process approved by the board. A preliminary report should be delivered to the board with enough time for the board to review it and require additional investigation—and with enough time to notify injured parties—prior to the December 5 deadline.

•  Board Reporting and Approval. The board should be presented with final findings and any necessary actions taken no later than December 5, 2025. Actions taken would include any required notices to injured parties, and any proposed updates to internal policies, practices, and procedures on a go-forward basis. Moreover, the board should approve the report to be submitted to the SBA prior to January 5, 2026. Review of the report by outside counsel prior to submission may be appropriate.

•  Submission of Report to SBA; Record Retention. A bank should submit its report to the SBA by the January 5, 2026 deadline. All records relating to the internal review, board action, and remediation efforts should be retained indefinitely.

I appreciate the information and time taken by Godfrey & Kahn for this guidance and for Peter to have joined in our webinar discussion with his insights. As mentioned previously in the webinar, I have posed several questions to SBA regarding their debanking letter and any clarifying information from SBA will be promptly shared with the membership.

Godfrey & Kahn is a WBA Gold Associate Member.

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Executive Letter: WBA Joins National Call for Treasury Review of Credit Unions

From the Desk of Rose Oswald PoelsBy Rose Oswald Poels

WBA joined with 52 other state bankers associations this summer in signing a joint letter to the U.S. Treasury Department. The letter urges the Treasury to conduct a study of the $2.37 trillion credit union industry and assess whether its current activities align with the tax-exempt status originally granted by Congress in 1934.

Congress created the Federal Credit Union Act over 90 years ago with the intent to expand access to affordable credit for people of modest means. Credit unions have since grown far beyond that mission, with more than 450 credit unions holding assets of at least $1 billion. Many operate nationally, acquire banks, sponsor professional sports teams, or generate tax-exempt income from affiliated businesses. In 2024 alone, credit unions acquired 22 banks with nearly $12 billion in assets.

The joint letter brings these trends into the spotlight as evidence that credit unions increasingly function like tax-paying banks while avoiding the same obligations of transparency and accountability. For example, federal credit unions are exempt from filing the IRS Form 990 that other nonprofits must submit, which leaves executive compensation and other data concealed from the public.

We are asking the Treasury to examine whether tax exemption is still justified, and to provide recommendations for legislative or regulatory changes. Among these could be requiring all credit unions to pay federal income tax and requiring federal credit unions to pay unrelated business income tax (UBIT) like other nonprofits.

The Treasury estimates that the credit union tax exemption will cost the government $32.2 billion by 2034, so this review is urgent and necessary. I believe this study will bring greater accountability and ensure that taxpayer dollars are not subsidizing institutions that have strayed far from their founding objective.

With 14 credit unions in Wisconsin now exceeding $1 billion in assets, WBA remains at the forefront of these discussions in Washington, D.C. We will continue to update our members as the Treasury considers next steps on this issue.

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Executive Letter: President Trump’s Executive Order on Debanking

From the Desk of Rose Oswald PoelsBy Rose Oswald Poels

Earlier in August, President Trump issued Executive Order 14331 called “Guaranteeing Fair Banking For All Americans.” Among other identified purposes, the Order states that: “Bank regulators have used supervisory scrutiny and other influence over regulated banks to direct or otherwise encourage politicized or unlawful debanking activities.”

The Order defines “politicized or unlawful de-banking” as any act by a financial institution to directly or indirectly restrict access to, or modify the conditions of, accounts, loans, or other banking services on the basis of a customer’s political or religious beliefs, or based on lawful business activities disfavored by the institution for political reasons.

Fair lending and related laws have existed for decades, and bankers have followed those laws throughout time. As a result, my initial view of the Order was that it is codifying or clarifying current law.

The order directs federal banking regulatory agencies to take various actions to implement intent. Many agencies, including FRB, OCC, and FDIC, have taken initial steps with their recent removal of reputational risk from supervisory expectations.

Additionally, the SBA sent a letter last week to lenders of actions to be taken by early December. Banks must review past and current policies that could be interpreted as encouraging politicized or unlawful de-banking and prepare a compliance report by January 5, 2026. Lenders failing to comply may risk punitive measures and lose good standing with the SBA.

These recent developments have once again inspired national attention around debanking and important questions about how they intersect with existing fair lending and other banking laws. I’ve fielded questions and concerns from our members about how these changes will affect daily bank operations, compliance practices, and relationships with customers.

WBA is committed to ensuring our members have the most current information and clarity. I invite you to attend our complimentary live webinar this Thursday, September 4, from 9:00 to 10:00 am CT. I will be joined by Peter Wilder, attorney with Godfrey & Kahn, as we review the executive order, SBA directives, and the current legal framework that governs fair lending.

This webinar is held specifically to support WBA bank members and will not be recorded in order to allow for candid discussions. We encourage you to bring questions

and participate in the Q&A session.

Registration is free but required. Please register one attendee per planned webinar connection to help us ensure sufficient capacity.

I look forward to speaking with you all on Thursday as we break down what these changes mean for your bank and your customers

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Executive Letter: The Penny Phase-Out

From the Desk of Rose Oswald PoelsBy Rose Oswald Poels

Earlier this year, the Treasury advanced President Trump’s plan to discontinue the penny. The final penny blanks are set to be minted in early 2026, and many members and their customers have a growing number of questions: Are pennies still available? Can banks continue to distribute pennies? How will businesses handle cash transactions moving forward?

Here are the key facts: 

  • Pennies are still legal tender. They remain useable for transactions, deposits, and withdrawals, though their availability will gradually decline as existing coins fall out of circulation. 
  • Production cost exceeds value. It costs about 3.7 cents to make a one-cent coin, marking the nineteenth consecutive year where manufacturing costs outweighed value.
  • Policy discussions are underway. Bills like the Common Cents Act seek to formalize this change and establish consistent rounding rules for cash transactions.
  • Other countries provide successful precedents. Canada, Australia, and New Zealand have successfully eliminated their lowest-denomination coins and use rounding rules for cash transactions. 
  • Estimated Effect on Consumers. Rounding cash transactions could cost U.S. consumers about $6 million per year in total, spread across millions of purchases. Most cash-users are unlikely to notice more than a penny or two difference over time.

All to say: Banks, businesses, and consumers will not be required to turn in pennies, nor will coins in circulation lose their value. Pennies would phase out slowly over time as they are spent. Cash transactions would likely be rounded to the nearest five cents, while digital transactions would remain exactly the same. 

I have recently heard from members that they are not able to order pennies in cash orders from the Federal Reserve. As a result of this change, I recommend members work with customers, particularly heavy cash-using business customers, to help them plan for the anticipated discontinuation. Perhaps consider a penny drive to collect pennies from customers similar to the efforts taken during COVID-19 times when coins were difficult to order from the Federal Reserve. This may help bridge a gap while customers and retailers adjust.  

WBA will continue to monitor policy developments to ensure our members have accurate information. We also encourage our members to keep an eye on our communications to prepare for customer questions on the penny phase-out.  

WBA remains committed to providing our industry with education and guidance during times of transition. We will continue to share updates as they become available. 

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Madison, WI 53718

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