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Tag Archive for: Executive Letter

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Advocacy, News

Executive Letter: WBA Advocacy Pays Off as the Trigger Lead Bill and ACRE Advance

From the Desk of Rose Oswald PoelsBy Rose Oswald Poels

This week brought encouraging news from Washington, D.C. as the Senate began taking steps on legislation to end predatory “trigger lead” practices. The Homebuyers Privacy Protection Act (S. 1467) seeks to prevent credit reporting agencies from selling consumers’ personal information after they apply for a mortgage. The House Financial Services Committee has already advanced an identical version of the bill (H.R. 2808), and with the Senate’s latest action, the measure is gaining strong momentum to move forward.

WBA has served as a persistent advocate for this legislation over the past two congressional sessions. Put simply: The bill champions consumer privacy. The measure aims to prevent credit bureaus from selling loan applicant data without consent, which leads to an influx of invasive solicitations from competing lenders. A mortgage application should be considered private information. Unwanted solicitations fatigue and confuse borrowers, which ultimately erodes trust in the mortgage process.

WBA has lobbied in support of trigger lead reform, and our message remains consistent: Borrowers deserve control over their personal data, and lenders should be able to serve their communities without interference from a relentless barrage of third-party offers.

Additionally, we are pleased to report progress on another top WBA priority: the Access to Credit for our Rural Economy (ACRE) Act. Yesterday, section 70435 of the Senate’s proposed budget reconciliation bill set forth a federal tax exemption for interest income derived from certain rural and agricultural real estate loans. In general, 25% of interest income earned on qualified real estate loans would be excluded from gross income at the federal level—a powerful step forward in reducing the cost of credit in rural areas.

All to say: ACRE eases the tax burden on interest income, which allows banks to reinvest more directly into rural communities—in turn supporting farmers, small businesses, and economic prosperity across our state.

Both developments mark important wins for Wisconsin banks and the clients we serve. We will continue our efforts to advance policies that protect borrowers. We encourage all members to join us on future advocacy trips to our nation’s capital. Thank you to all the bankers who have joined the chorus of support—your advocacy makes a difference!

June 19, 2025/by Katie Reiser
https://www.wisbank.com/wp-content/uploads/2024/12/Executive-Letter-Thumbnail.png 720 1280 Katie Reiser https://www.wisbank.com/wp-content/uploads/2021/09/Wisconsin-Bankers-Association-logo.svg Katie Reiser2025-06-19 07:26:122025-06-19 07:26:12Executive Letter: WBA Advocacy Pays Off as the Trigger Lead Bill and ACRE Advance
Advocacy, News

Executive Letter: Banking Wins and Risks in “One Big Beautiful Bill”

From the Desk of Rose Oswald PoelsBy Rose Oswald Poels

The House-passed “One Big Beautiful Bill Act” (H.R. 1) included a few key wins for the banking industry — importantly, a modified version of the ACRE Act that would help to enhance competition with government-backed farm lenders and tax relief for Subchapter S banks.

Now that the bill is in the hands of the Senate, WBA has been advocating publicly and behind the scenes with our U.S. Senators to underscore how vital it is that the Senate version of the bill include at least the same modified version of ACRE as in the House bill. In coalition letters to Senate leadership, we have also requested increases to the tax exemption percentage from that contained in the House version. Finally, we continue to support the inclusion of tax relief for Subchapter S banks.

Additionally, WBA recently learned of a different provision in the House version of the bill that could become burdensome for financial institutions. A provision in the legislation would impose a 3.5% tax on all cross-border remittance transfers made by any non-U.S. citizen — applying not only to individuals remitting money, but also to all bank-to-bank cross border transfers. The language in the House version does not distinguish between remittances sent by non-citizens who are in the U.S. legally or illegally, which means the scope reaches to non-citizen business owners who are in the U.S. legally conducting their business will be subject to the 3.5% excise tax every time they transfer money out of the U.S. Banks will have to verify the citizenship status of the remittance requestor and, if that requestor is not a U.S. citizen, banks will have to collect and remit the tax to the U.S. Treasury.

Finally, the House version creates a new account called the “Trump Account” which would place $1,000 into an investment account for every newborn in the U.S. As written, the funds are placed into stock market index funds, managed by the child’s legal guardians, with the goal of building long-term financial security.

WBA will keep members apprised of these and other relevant developments as the language continues to evolve.

June 12, 2025/by Katie Reiser
https://www.wisbank.com/wp-content/uploads/2024/12/Executive-Letter-Thumbnail.png 720 1280 Katie Reiser https://www.wisbank.com/wp-content/uploads/2021/09/Wisconsin-Bankers-Association-logo.svg Katie Reiser2025-06-12 08:06:012025-06-12 08:06:01Executive Letter: Banking Wins and Risks in “One Big Beautiful Bill”
Member News, News

Executive Letter: Advancing Together — A Year of Impactful Accomplishments

From the Desk of Rose Oswald PoelsBy Rose Oswald Poels

As WBA’s 2024–2025 fiscal year comes to a close this week, I want to extend my sincere gratitude to you and your team for your continued membership in and support of WBA. As I reflect on the past fiscal year, it is clear that the strength of our Association lies in the active involvement of members like you, and I am proud of all we have accomplished together to support a strong, innovative, and resilient banking industry in Wisconsin.

WBA’s impact this year has been substantial. On the regulatory front, we worked closely with the Wisconsin Department of Revenue to implement the new state income tax exemption — an historic, WBA-led legislative win that is expected to deliver our industry at least $29 million in tax savings annually. We also successfully defended the industry by preventing harmful interchange and merchant category code legislation and advanced modernization efforts through updates to the Wisconsin Trust Code and other laws.

Beyond advocacy, WBA offered over seventy-five in-person education programs attended by more than 6,000 bankers, delivered timely legal and compliance resources, and continued to help members reduce benefit costs — saving banks over $2.7 million through our Association Health Plan. You will find more details about these and other significant accomplishments in the July/August 2025 “Year in Review” issue of Wisconsin Banker.

Looking back on our numerous advocacy successes and the valuable resources we have delivered to members, I am energized and optimistic about the collaborative progress we will make in the 2025–2026 fiscal year.

I also want to thank WBA Board Chair Al Araque, the Officers and the rest of the 2024–2025 WBA Board, for their impactful leadership, engagement, and support this past year. Together, the membership, Board, and staff accomplished a lot for the benefit of the industry!

Please watch for your WBA dues invoice for the upcoming 2025–2026 fiscal year, which begins June 1. If you have any questions about your invoice or membership, don’t hesitate to reach out to me directly. I look forward to continuing to work with and for you in the year ahead.

May 29, 2025/by Katie Reiser
https://www.wisbank.com/wp-content/uploads/2024/12/Executive-Letter-Thumbnail.png 720 1280 Katie Reiser https://www.wisbank.com/wp-content/uploads/2021/09/Wisconsin-Bankers-Association-logo.svg Katie Reiser2025-05-29 07:33:262025-05-29 07:33:26Executive Letter: Advancing Together — A Year of Impactful Accomplishments
Advocacy, Member News

Executive Letter: More Advocacy in Action

From the Desk of Rose Oswald PoelsBy Rose Oswald Poels

The banking industry has been very active this spring with our legislative advocacy at the state and federal level. I am excited to share that, once again, we had incredibly strong participation from Wisconsin bankers last week when WBA joined with ICBA for their annual Capital Summit in Washington, D.C. This year, 21 Wisconsin bankers, two ICBA staff members, and one person from FHLBank of Chicago joined Daryll and me for Congressional Hill visits on key banking industry legislation. Between our two spring Washington trips, we had 43 bankers (several of whom joined us for the first time) join WBA this year, which is a number we have not seen since pre-COVID years. Thank you all for listening to our requests to increase your personal involvement in these critical advocacy trips!

Like last month, the timing of our Hill visits last week Wednesday was fortuitous as both tax policy and cryptocurrency were hot topics in Washington D.C. As you see in the news, there is a lot of focus on passing the House reconciliation bill, labeled the “One Big Beautiful Bill Act,” and sending it to the Senate. This legislation is certainly not without a lot of controversy; however, when the tax portion was first published by the House Ways and Means Committee, WBA was very excited to see a modified version of the ACRE Act included. This is extremely significant because out of hundreds of requests for new tax law changes, only a handful were included and modified ACRE is one of them. Without significant grassroots involvement from the industry over the last several congressional sessions, I do not think this provision would have been included. I am pleased to share that currently Reps. Steil, Fitzgerald, Van Orden, and Pocan are co-sponsors of the stand-alone ACRE Act legislation.

In addition to discussing tax policy and the ACRE Act, there was a lot of dialogue with each Wisconsin congressional office on cryptocurrency. It is expected that the GENIUS Act in the Senate will be up on the floor for a vote this week, and the STABLE Act is expected to progress further in the House soon. Primarily our message was to mitigate stablecoin risks while protecting against community bank disintermediation. Other topics covered included Section 1071 legislation, Credit Card Competition Act, the Farm Bill, and Trigger Leads.

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 year for one of our two annual Washington Trips, or later this year when we meet with regulators (not legislators), October 16–17, 2025.

Thank you to the bankers who attended the WBA/ICBA Capital Summit!

  • Justin Adamski, The Pineries Bank, Stevens Point
  • Robin Christian, Premier Community Bank, Marion
  • Brooke Frehse, The Stephenson National Bank & Trust, Marinette
  • Rachael Gadbois, The Pineries Bank, Stevens Point
  • Mike Gargaro, Citizens First Bank, Trempealeau
  • Jeff Gruetzmacher, Royal Bank, Lancaster
  • Dale Hans, Horicon Bank
  • Donna Hoppenjan, Mound City Bank, Platteville
  • Shane Ilstrup, Citizens First Bank, Trempealeau
  • Jimmy Kauffman, Bank of Sun Prairie
  • Sue Loken, Lake Ridge Bank, Middleton
  • Hope Markhardt, Lake Ridge Bank, Madison
  • Josh Marron, Park Bank, Madison
  • Paul Northway, American National Bank Fox Cities, Appleton
  • Mike Olson, The Bank of Brodhead
  • Butch Pomeroy, International Bank of Amherst
  • Lonnie Przybylski, International Bank of Amherst
  • Dan Ravenscroft, Royal Bank, Elroy
  • Julie Redfern, Lake Ridge Bank, Verona
  • Ron Schaaf, The Bank of New Glarus
  • Justin Wroblewski, The Stephenson National Bank and Trust, Marinette

Thanks also to these individuals for joining our group:

  • Dave Feldhaus, Federal Home Loan Bank of Chicago
  • Julie Hanson, ICBA
  • Sean Murphy, ICBA
May 22, 2025/by Katie Reiser
https://www.wisbank.com/wp-content/uploads/2024/12/Executive-Letter-Thumbnail.png 720 1280 Katie Reiser https://www.wisbank.com/wp-content/uploads/2021/09/Wisconsin-Bankers-Association-logo.svg Katie Reiser2025-05-22 07:17:362025-05-22 08:49:54Executive Letter: More Advocacy in Action
Advocacy, Community, Member News, News

Executive Letter: Record-Breaking Capitol Day Demonstrates Power of Unified Industry Voice

From the Desk of Rose Oswald PoelsBy Rose Oswald Poels

I want to extend my sincere thanks to all of the members who helped make our 2025 Capitol Day a resounding success. With over 320 bankers from more than 70 banks across Wisconsin in attendance, this year marked record-breaking participation and sent a powerful message to lawmakers at the State Capitol.

Bankers met with 32 of 33 State Senators and 80 of 99 State Representatives to discuss the critical role banks play in growing local economies and supporting the needs of individuals, families, and businesses. These direct conversations — on topics like state privacy regulations, credit card interchange fees, tax parity, cryptocurrency, and protecting seniors from financial fraud — emphasized how essential strong partnerships are between lawmakers and our industry. The presence of such a large, unified group made a lasting impression on our state’s elected officials.

We heard from key state leaders including Senate Majority Leader Devin LeMahieu, Senate Minority Leader Dianne Hesselbein, Assembly Speaker Robin Vos, and Assembly Assistant Minority Leader Kalan Haywood who participated in a panel moderated by WisPolitics.com President Jeff Mayers. During lunch, remarks were delivered by DFI Secretary-designee Wendy K. Baumann. Their participation reaffirmed the importance of Capitol Day in shaping policies that enable banks to better serve Wisconsin communities.

As we continue our advocacy work in 2025, we are actively working toward our annual fundraising goal of $300,000 through contributions to Wisbankpac and the Alliance for Bankers Conduit. These funds are essential to supporting critical efforts like Capitol Day — which remains free for WBA members — and ensuring the voice of Wisconsin’s banking industry remains strong and effective in the legislative process. If you or others at your bank have not yet participated, I encourage you to consider a personal contribution and help us reach this important goal. If you would like to help spread the word about WBA’s fundraising goal, a sample fundraising letter is in the digital WBA Advocacy Toolkit.

Once again, thank you for your leadership and your commitment to advocacy. Together, we are making a difference in advancing the banking industry and supporting communities across the state.

If you would like to access any of the “leave behind materials” shared at Capitol Day, you can download them from the links below:
•  WBA Issue Papers Summary
•  Issue Summary
•  Impact Brochure

In closing, I’d like to give kudos to WBA’s Government Relations team, Lorenzo Cruz and Tyler Foti, for their hard work in making Capitol Day the success that it was.

May 15, 2025/by Katie Reiser
https://www.wisbank.com/wp-content/uploads/2024/12/Executive-Letter-Thumbnail.png 720 1280 Katie Reiser https://www.wisbank.com/wp-content/uploads/2021/09/Wisconsin-Bankers-Association-logo.svg Katie Reiser2025-05-15 07:47:382025-05-15 07:47:38Executive Letter: Record-Breaking Capitol Day Demonstrates Power of Unified Industry Voice
Community, Member News, News

Executive Letter: Celebrating the Power of Community and the Impact of Wisconsin’s Bankers

From the Desk of Rose Oswald PoelsBy Rose Oswald Poels

April is always an action-packed month. I am proud to reflect on the conclusion of another successful Community Banking Month, Financial Literacy Month, WBA Power of Community Week, and Teach Children to Save Day. Each year, these initiatives remind me just how deeply rooted our member banks are in the communities they serve—not only as financial institutions but as active participants in making Wisconsin stronger.

During Power of Community week, WBA staff also rolled up their sleeves and volunteered at the Aldo Leopold Nature Center and Habitat ReStore of Dane County, contributing to projects that help preserve our environment and support affordable housing. In addition, our team organized a bake sale, raising over $300 for Second Harvest Foodbank, and collected much-needed items for The Road Home to assist families experiencing housing insecurity. With additional money from WBA, donations totaling $500 were made to The Road Home and Second Harvest Foodbank. These efforts reflect the same generous spirit of service we see across the state from member banks and their employees.

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While I take this opportunity to celebrate WBA staff contributions and volunteerism, I also want to extend my thanks and congratulations to all the banks across Wisconsin that participated in Power of Community Week — and to those that give back year-round. Whether it’s through supporting local nonprofits, hosting community events, or offering your expertise to help customers thrive, your commitment makes a tangible difference.

Always a popular and impactful initiative is Teach Children to Save Day, which saw increased engagement from bankers this year as they helped students develop lifelong financial skills. A record number of banks requested WBA’s Reading Raises Interest kits in 2025. This year’s featured book, “Rock, Brock and the Savings Shock,” was a hit with elementary students statewide and served as a fun and engaging way to introduce savings concepts at an early age.

As we look ahead, I encourage every bank that participates in financial education initiatives to complete the Financial Education Summary Forms available through the Wisconsin Bankers Foundation (WBF). In order to capture and celebrate the many ways bankers volunteer their time and expertise to foster financial literacy, the Foundation collects this information annually. These summaries help guide the work of both WBA and WBF staff, and importantly, they are shared with elected officials and community members to highlight the collective contributions of our industry. If your bank employees hosted a financial education presentation (between June 1, 2024, and May 31, 2025) encourage them to submit the forms by July 31.

By reporting your efforts, you help ensure that the value of financial education — and the essential role that bankers play in delivering it — is widely recognized and supported. Additionally, individual employees and your bank may be eligible for the Financial Education Awards from the Foundation.

Thank you again for your partnership and your commitment to powering communities throughout our state.

May 8, 2025/by Katie Reiser
https://www.wisbank.com/wp-content/uploads/2024/12/Executive-Letter-Thumbnail.png 720 1280 Katie Reiser https://www.wisbank.com/wp-content/uploads/2021/09/Wisconsin-Bankers-Association-logo.svg Katie Reiser2025-05-08 07:30:522025-05-08 07:30:52Executive Letter: Celebrating the Power of Community and the Impact of Wisconsin’s Bankers
Advocacy, News

Executive Letter: WBA Advocacy in Action — Protecting Mortgage Customers from Unwanted Solicitations

From the Desk of Rose Oswald PoelsBy Rose Oswald Poels

With the 119th Congress well underway, more legislation is getting introduced to help the industry and its customers. While WBA was in Washington D.C. a few weeks ago for the first of two Washington lobby trips, we spoke with our congressional delegation about the need for the “trigger lead” bill to be reintroduced this session. Later that week, the bipartisan Homebuyers Privacy Protection Act was introduced in both the Senate and House (S. 1467 and H.R. 2808) and is currently co-sponsored by Senator Baldwin and Rep. Bryan Steil respectively.

As a reminder, the Homebuyers Privacy Protection Act would amend the Fair Credit Reporting Act to eliminate abusive mortgage “trigger leads” and limit prescreened credit offers to consumers who consent or who have a preexisting relationship with a financial institution. Currently, the only way for a consumer to not receive these prescreened offers is by expressly opting out on each credit bureau’s website.

The Senate bill was introduced and immediately referred to the Senate Committee on Banking, Housing and Urban Affairs. The House bill was introduced and immediately referred to the House Financial Services Committee. Today, H.R. 2808 is being noticed as part of a House Financial Institutions Subcommittee hearing.

Since the beginning of last session, WBA has been lobbying for passage of this bipartisan legislation alongside ABA and ICBA. All bankers attending our Washington lobby trips over the last few years share stories about the incredibly high number of phone calls and text messages their mortgage applicants receive within hours of applying for a mortgage loan. These entities that have no relationship with the consumer are buying these trigger leads from the credit bureaus and immediately contacting your customers to lure them away from your bank. These calls have left customers confused and very upset, often believing that the bank has improperly shared their information.

To help banks warn their customers about the problem, WBA created model forms members may use to communicate this activity at the application stage which reiterates that the bank did not sell the customer’s information. You may obtain the forms from the WBA Best Practices Library located on the compliance resources section of the WBA website. The library is password protected. If you need the password, please contact WBA Legal at wbalegal@wisbank.com

WBA will be back in Washington D.C. with bankers in a few weeks in conjunction with ICBA’s Capital Summit where we will lobby on this legislation, among others, to get more Wisconsin co-sponsors added. Last session, several members of our delegation were co-sponsors. In addition, ICBA has a banker “call to action” on the trigger leads bill on its “Be Heard Grassroots Action Center” which can be accessed here: ICBA urges grassroots action on trigger leads. I encourage you to let your member of Congress know this is a critical issue for your bank’s customers!

May 1, 2025/by Katie Reiser
https://www.wisbank.com/wp-content/uploads/2024/12/Executive-Letter-Thumbnail.png 720 1280 Katie Reiser https://www.wisbank.com/wp-content/uploads/2021/09/Wisconsin-Bankers-Association-logo.svg Katie Reiser2025-05-01 08:54:192025-05-01 08:54:19Executive Letter: WBA Advocacy in Action — Protecting Mortgage Customers from Unwanted Solicitations
Member News, News, Resources

Executive Letter: Staying Ahead Together — New Member Resources on Emerging Industry Issues

From the Desk of Rose Oswald PoelsBy Rose Oswald Poels

Staying ahead of the curve is a constant priority for our industry — and it’s one the Association takes seriously. WBA is committed to evolving alongside you, offering timely programming that addresses the most pressing issues facing Wisconsin’s banks. Your input drives our work, and our latest offerings reflect both your concerns and your need for accessible, relevant resources.

On April 21st, WBA hosted Fraud Trends & Prevention Strategies, a free webinar presented by Paul Benda, Executive Vice President for Risk, Fraud, and Cybersecurity at the American Bankers Association. From the alarming rise in check fraud to the growing impact of artificial intelligence and deepfakes, Benda provided valuable insights and practical approaches to an increasingly complex threat landscape. His real-life example of the ease in which deep fake recordings can be created with the help of AI was chilling.

Not only did Benda trace the history and predict the trajectory of fraud, he shared how banks can stay one step ahead of bad actors by taking advantage of available resources and working cooperatively with other financial institutions. In addition to covering relevant data and best practices, Benda described advocacy efforts to mitigate fraud. In Wisconsin WBA saw several wins on that front in the last session and will continue to push for legislative change to protect customers.

Member feedback has been overwhelmingly positive. If you missed it — or would like your team to review the material — the recording and slides are available for members for the next 30 days. Please email wbaeducation@wisbank.com to request those resources.

Recognizing that fraud remains a top concern, WBA is expanding on this topic with a new WBA Fraud Summit, scheduled for June 3, 2025, in Wisconsin Dells. This in-person event will bring together industry experts and banking professionals to explore trends, share ideas, and identify strategies to strengthen fraud defenses. We hope members of your team will plan to attend. Click here to learn more and register.

Additionally, we are pleased to offer another no-cost educational webinar: Crypto in 2025: What You Need to Know, presented virtually on Thursday, May 8 from 10:00–11:00 a.m. CT. Brian Laverdure, ICBA’s SVP of Digital Assets and Innovation Policy, will provide a clear-eyed perspective of the regulatory outlook, the evolution of stablecoins, and emerging risks associated with crypto-related illicit finance. Click here for more details.

As always, I appreciate your engagement with WBA programs and services. Our education team is focused on delivering programming that meets your needs and supports your bank’s continued success.

April 24, 2025/by Katie Reiser
https://www.wisbank.com/wp-content/uploads/2024/12/Executive-Letter-Thumbnail.png 720 1280 Katie Reiser https://www.wisbank.com/wp-content/uploads/2021/09/Wisconsin-Bankers-Association-logo.svg Katie Reiser2025-04-24 08:09:332025-04-24 08:09:33Executive Letter: Staying Ahead Together — New Member Resources on Emerging Industry Issues
Advocacy, Member News, News, Uncategorized

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

April 17, 2025/by Katie Reiser
https://www.wisbank.com/wp-content/uploads/2024/12/Executive-Letter-Thumbnail.png 720 1280 Katie Reiser https://www.wisbank.com/wp-content/uploads/2021/09/Wisconsin-Bankers-Association-logo.svg Katie Reiser2025-04-17 07:27:362025-04-17 07:27:36Executive Letter: Advocacy in Action
Compliance, News, Resources

Executive Letter: New Section 1071 Proposed Rule Expected Soon

From the Desk of Rose Oswald PoelsBy Rose Oswald Poels

In court filings last week involving the Bureau of Consumer Financial Protection’s (CFPB) Section 1071 rule, the CFPB stated that staff have been instructed to initiate new rulemaking to possibly replace or change the current rule. While I do not know yet what specific changes CFPB has planned for its new rulemaking, I am very pleased to have learned of this news as WBA has been vocal in our objections and concerns of Section 1071 since it was first proposed in the fall of 2021. In addition, last week the House Financial Services Committee voted on April 2 to approve H.R. 976, which would repeal Section 1071 in its entirety.

The Dodd-Frank Act directed CFPB to adopt a regulation to require banks to collect certain lending data from small businesses. This provision of the Act, Section 1071, was first implemented in March 2023 through amendments to Regulation B which implements the Equal Credit Opportunity Act (ECOA). The original effective date of the 2023 final rule was August 29, 2023, with rolling mandatory compliance dates ranging from October 1, 2024, to January 1, 2026, based upon loan origination activity.

Due to litigation by lenders challenging the rule, the mandatory compliance dates for the Section 1071 rule were extended by CFPB on June 25, 2024, through the issuance of an interim final rule. In February, the Fifth Circuit granted a stay in the ongoing litigation which further tolled the compliance dates for financial institutions that are also members of the trade associations involved in the lawsuit.

In the past, when I have been asked by members whether the bank should work to implement the requirements of Section 1071 despite the ongoing litigation and our industry efforts to rollback or eliminate the rule, my recommendation has been for banks to continue their efforts to meet the revised mandatory compliance dates for the rule. However, given the change in the Administration, the litigation status, last week’s movement of repeal legislation and news of a new proposed Section 1071 rule, I believe banks should take a temporary pause pending the outcome in one or more of these actions.

The industry has challenged the Section 1071 rule on all fronts over the years – through legislation, regulation, and judicial action. While a new proposed rule is not yet published, WBA will advocate for the elimination of a requirement to collect any data beyond that expressly provided for under the Dodd-Frant Act. WBA will also advocate for CFPB to revise the definitions of “covered financial institutions” and “small business” to raise both thresholds within. WBA is also continuing its legislative advocacy this week while we are in Washington D.C. with a banker delegation as part of ABA’s Washington Summit for the full repeal of Section 1071, encouraging continued support of H.R. 976.

WBA will continue to keep members apprised of these various changes regarding Section 1071 as they occur. If you have any questions regarding Section 1071, be sure to reach out to WBA Legal at wbalegal@wisbank.com

April 10, 2025/by Katie Reiser
https://www.wisbank.com/wp-content/uploads/2024/12/Executive-Letter-Thumbnail.png 720 1280 Katie Reiser https://www.wisbank.com/wp-content/uploads/2021/09/Wisconsin-Bankers-Association-logo.svg Katie Reiser2025-04-10 06:24:312025-04-10 06:24:31Executive Letter: New Section 1071 Proposed Rule Expected Soon
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