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August 2026 Compliance Journal

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Compliance Journal August 2026

Special Focus The Long Tail of PPP Why Bank Customers are Being Targeted Again Jeff Otteson, vice president of sales, with the Midwest Bankers Insurance Services (MBIS) offers the following information about how scams involving Paycheck Protection Program (PPP) information work, why the fraudsters are so convincing, steps banks can take to help mitigate the fraud, and insurance considerations. The PPP may have ended, but the information it generated continues to create opportunities for fraudsters. Businesses that received PPP loans are now being targeted through highly personalized bank-impersonation schemes. Using publicly available PPP loan information, criminals can identify a business, its loan amount and, in many cases, the bank associated with the loan. That information gives a fraudster enough credibility to make an unexpected call, text message, or email sound legitimate. This is not simply another generic phishing campaign. It is a targeted social-engineering attack built around real information and a trusted banking relationship. How the Scam Works The Small Business Administration maintains a public, loan-level dataset covering disbursed PPP loans. Fraudsters can combine that data with business websites, social media, and other public records to develop a convincing profile of a potential victim. A fraudster may know: • The business’s legal name and address; • The amount of its PPP loan; • The lender associated with the loan; • The names of owners, executives, or accounting employees; and • The bank’s treasury-management or fraud-department terminology The criminal then contacts the business while impersonating an employee of its bank. Caller ID may be spoofed so the call appears to originate from the bank’s actual telephone number. Emails and text messages may use the bank’s name, logo, and branding. The purported reason for the contact can vary. The customer may be told that: • A suspicious ACH or wire transfer is pending; • Someone attempted to access the company’s online banking account; • A check or electronic payment must be verified; • The account must be frozen to prevent additional fraud; • A security update is required; • The bank needs to confirm the customer’s credentials; or • A one-time passcode is needed to stop or reverse a transaction.


Special Focus The fraudster creates urgency and positions himself as the person trying to protect the customer. In reality, the criminal may already possess the customer’s username and password. The call is designed to obtain the final piece needed to defeat multifactor authentication: the customer’s one-time security code. The FBI has specifically warned about account-takeover schemes involving criminals impersonating financial institution support personnel. Once the customer provides the requested code, the fraudster may gain access to the account, establish a new device, change contact information, or initiate unauthorized ACH and wire transfers. Why These Calls Are So Convincing Traditional fraud-awareness training often instructs customers to look for spelling mistakes, unfamiliar senders, or vague messages. Those warning signs may not be present here.

August 2026 Volume 32, Number 3 Wisconsin Bankers Association 4721 South Biltmore Lane, P.O. Box 8880, Madison, Wisconsin, 53708-8880

The caller may correctly identify the customer’s bank, PPP loan, and business information. The telephone number appearing on caller ID may match the number printed on the back of the customer’s debit card or listed on the bank’s website. The criminal may even transfer the victim between several supposed departments to create the appearance of a legitimate financial institution.

Senior Writers Heather MacKinnon Scott Birrenkott

The use of accurate information does not make the caller legitimate. It only demonstrates that the criminal has done research.

Layout Emily Torgerson

Bank customers should understand that caller ID is not a reliable authentication method. A person who receives an unexpected banking call should hang up and contact the bank through a telephone number the customer independently knows to be correct, not a number provided by the caller or contained in an unsolicited message. What Banks Should Be Telling Their Customers Banks should communicate directly with business customers, particularly customers identified in public PPP data. The message should be simple and specific: The bank will never call and ask a customer to disclose a password, authentication token, or one-time security code. Customers should also be reminded that a code generated by multifactor authentication is not merely an identification number. It may authorize access, approve a new device, or permit a transaction. Providing that code to another person can be the digital equivalent of handing over a key to the account. Additional customer guidance should include: • Never provide usernames, passwords, PINs, tokens, or one-time passcodes in response to an incoming call, email, or text. • Do not click an online-banking link contained in an unsolicited message. • Access online banking through the bank’s official website or mobile application. • Hang up and call the bank using a known, independently verified telephone number. • Require dual control for ACH and wire activity. • Establish transaction and daily exposure limits that reflect the company’s actual needs. • Review new users, authorized devices, and changes to account contact information. • Enable alerts for password changes, new-device enrollment, and outgoing transactions. • Report suspicious communications immediately, even if no money appears to have left the account. Prompt reporting can help prevent or limit a loss. Customers should not wait until the next business day if they believe credentials or authentication codes have been disclosed. Page 2 | August 2026

Editor Ramon Morales

Copyright ©2026 Wisconsin Bankers Association. All rights reserved. Reproduction by any means of the entire contents or any portion of this publication without prior written permission is strictly prohibited. This publication is intended to provide accurate information in regard to the subject matter covered as of the date of publication; however, the information does not constitute legal advice. If legal advice or other expert assistance is required, the services of a competent and professional person should be sought.


Special Focus Banks Must Also Examine Their Own Procedures Customer education is only one part of the response. Banks should review how employees handle calls involving compromised credentials, new-device enrollment, changes to telephone numbers or email addresses, and requests to add new treasury-management users. A fraudster who has compromised a customer’s email account may attempt to add a supposed new CFO or controller to the customer’s wire agreement. The request may come from the customer’s legitimate email address, but that does not establish that the request is authorized. Material changes to authorized users, callback numbers, transaction authority, or security procedures should be independently verified with an existing authorized person using previously established contact information. Employees should not rely on the telephone number or contact information contained in the request being verified. The bank should also confirm that its written wire-transfer agreement clearly identifies: • Who is authorized to request wires; • The predetermined telephone number to be used for callbacks; • The PIN or passcode the requester must verify during the callback; and • The procedures for changing authorized persons or callback information. Having a written agreement is only the beginning. Employees must consistently follow the security procedures contained in it. A callback to a number supplied in the fraudulent request is not an effective callback. Similarly, completing a callback without requiring the agreed-upon PIN or passcode may undermine the protection the procedure was designed to provide. The Insurance Question Is More Complicated Than It Appears When an account-takeover loss occurs, the customer, bank, and their respective insurers may all examine who was compromised, who authorized the transaction, and which security procedures were followed. Coverage is highly dependent on the specific facts and policy language. A bank’s Financial Institution Bond may distinguish between a direct compromise of the bank’s systems and a loss resulting from a customer voluntarily providing credentials or authentication codes. Computer-fraud, funds-transfer, fraudulent-instruction, and social-engineering provisions may contain materially different definitions, exclusions, and authentication requirements. The customer’s cyber or crime policy may also be relevant, particularly when the customer’s employee was deceived into disclosing credentials or approving a fraudulent transaction. However, the existence of insurance should never be assumed to eliminate the potential dispute between the customer and the bank. Banks should review both their operational procedures and insurance coverage before a loss occurs. That review should address customer credential compromise, account takeover, new-device authorization, fraudulent changes to authorized users, and the failure to follow agreed callback or authentication procedures. The Takeaway for Community Banks PPP data has created a lasting roadmap that criminals can use to identify businesses and their banking relationships. The immediate scam may target the customer, but the resulting financial loss, customer dispute, and reputational damage can quickly reach the bank. Community banks are particularly well positioned to respond because they know their customers and can communicate with them directly. A timely warning from a trusted relationship manager may be more effective than a general fraud notice posted on a website. Banks should not treat the end of the PPP lending period as the end of PPP-related risk. The loans may have been forgiven, but the publicly available information remains—and criminals are finding new ways to use it. WBA thanks Jeff Otteson, vice president of sales at MBIS, a WBA subsidiary, for contributing this article; for more information, contact Jeff at jeffo@mbisllc.com or 608-217-5219. August 2026 | Page 3


Special Focus DOT Warns of Auto Dealership Spoofing The Wisconsin Department of Transportation (DOT) has reported on a recent trend where scammers pose as vehicle dealers online. DOT started tracking this pattern back in 2024 but has recently alerted WBA that they are seeing the scheme on the rise again in 2026. This scheme, often referred to as “dealer cloning,” begins with a fake storefront. The criminals establish an online presence (through a website, social media, or even a fake review page) claiming to be a Wisconsin dealership. In some cases, the criminals have spoofed real, legitimate, licensed Wisconsin dealers. This article is designed to provide information on this scam, how to spot it, and how to assist customers who might be at risk of falling for dealer cloning fraud. Key Aspects of the Scheme Fake dealership sites appear legitimate. Indeed, their format, layout, images, and logos are often reproduced, stolen, or otherwise hijacked from legitimate websites. The criminals use real photos of real vehicles, including stock images, or photos ripped from actual dealerships. The vehicles on these pages are frequently listed below market value in an effort to draw consumers in. Fraudsters will typically interact with the potential buyer electronically, although DOT has reported they have communicated directly by phone as well. Since the dealership is fake, the transaction is entirely online. In fact, DOT has reported cases where criminals have even offered a discount to consumers simply to stop them from coming out to the dealership’s physical presence (which does not exist) in order to maintain the fraud. The criminals request payment typically by wire and assure the buyer they will ship the vehicle directly to them upon payment. According to DOT, there is a consistent pattern they have been tracking whereby a fake website, or social media page appears, featuring below-market price (often luxury vehicles, but sometimes including others as well, and even motorcycles), with no in-person contact. In some instances, the business behind the site never existed at all. DOT reported that in 2024 alone, its Field Investigation Unit investigated 1,259 consumer complaints on this issue. Considerations for Compliance, BSA, and Security Programs While this may seem like one scam among many, it is important to be aware of trending schemes to be better suited to spot them. As with all fraud, time and pressure are tools used by the criminals. They will pressure potential buyers with a deal and the threat of a limited offer. Bank customers, eager to take advantage of the deal, will be looking to withdraw money or send a wire. While banks do not know all the details of every transaction, there may be indicators a bank can spot to warn a customer that the deal may be fraudulent and give customers an opportunity to use DOT’s resources and avoid being scammed. For example, • Mismatched or erroneous name, address, and contact information as part of a wire (e.g., the receiving account holder’s name does not match the dealership name). • If a customer is excited to share of a deal they received that sounds too good to be true, features no in-person contact with the seller, and reluctance or refusal on the seller’s part to have the vehicle inspected before payment. • A dealership that cannot be verified independently (e.g., by phone, address, or email obtained outside the website itself). • A dealership that does not appear on DOT’s licensed dealer list. • A bill of sale or purchase contract that is missing, informal, or does not resemble Wisconsin’s required Motor Vehicle Purchase Contract. While Wisconsin law does not require banks to take any particular steps regarding dealer cloning scams it is important to be aware of fraud that potentially impacts bank customers. DOT Press Release: https://wisconsindot.gov/Pages/about-wisdot/newsroom/news-rel/022425clonescam.aspx DOT Licensed Dealer Information: https://wisconsindot.gov/Pages/dmv/dlr-agents/tips-tls-dlr/buyerslicissued.aspx DOT Consumer Rights Page: https://wisconsindot.gov/Pages/dmv/cons-protect/know-rghts/knowyourrights.aspx

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Special Focus FinCEN Eliminates Most BOI Reporting by Business Customers to FinCEN The Financial Crimes Enforcement Network (FinCEN) recently issued a final rule that narrows the beneficial ownership information (BOI) reporting under the Corporate Transparency Act (CTA). As bankers may be fielding questions regarding the rule from business customers, the following article is presented as a short summary of what the final rule means, as well as links to additional resources. Importantly, BOI reporting under the CTA applies only to “reporting companies” (which is discussed more below). It is also worth noting that the final rule relates only to BOI reporting by a reporting company. Nothing has changed regarding a bank’s obligations under the Bank Secrecy Act-related Customer Due Diligence (CDD) rule. Banks must still comply with the requirements of the CDD rule. As a quick matter of background, FinCEN previously issued an interim final rule in March, 2025 which narrowed BOI reporting requirements by reporting companies. The final rule permanently adopts that narrowing by finalizing certain exemptions. Summary of Changes As discussed above, the core of the final rule is to permanently adopt the exemptions provided by the March 2025 interim final rule. The final rule adopts all changes made by the interim final rule as permanent changes to BOI reporting requirements. This includes eliminating the requirement for U.S. companies and U.S. persons to report BOI to FinCEN. The final rule also exempts foreign companies from the requirement to report U.S. person “company applicants” (i.e., the individuals who helped a foreign company register to do business in the U.S.) and exempts U.S. persons who have applied for FinCEN identifiers (FinCEN IDs) from having to update or correct the information they provided to FinCEN when they applied. Only entities formed under foreign law and registered to do business in a U.S. state or tribal jurisdiction remain “reporting companies.” FinCEN also confirmed it will purge information about company applicants, beneficial owners, or FinCEN ID holders that it reasonably believes belongs to a U.S. person. Conclusion As a reminder, the final rule places no new requirements upon banks nor does it alter existing CDD requirements for banks. Bankers who receive questions from customers may find the following additional resources helpful to refer the customers to for more information. FinCEN will also be updating guidance on its website to reflect the final rule. FinCEN Final Rule: https://www.govinfo.gov/content/pkg/FR-2026-08-14/pdf/2026-16576.pdf FinCEN Press Release: https://home.treasury.gov/news/press-releases/sb0603 FinCEN BOI FAQs: https://www.fincen.gov/system/files/2026-08/QAs_BOIFinalRule.pdf FinCEN BOI Webpage: https://www.fincen.gov/boi

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Regulatory Spotlight Agencies Confirm No Inflation Adjustment to CMPs. The Board of Governors of the Federal Reserve System (FRB) announced that pursuant to the Federal Civil Penalties Inflation Adjustment Act Improvements Act, FRB’s civil money penalty (CMP) amounts will not increase for 2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-07-13/pdf/2026-14060.pdf. Federal Register, Vol. 91, No. 132, 07/13/2026, 42962. The Department of Veterans Affairs (VA) announced it will make no change in regulation to adjust for inflation the amount of civil monetary penalties (CMPs) that are allowed within VA’s authorities. The notice is in accordance with the requirement in the Federal Civil Penalties Inflation Adjustment Act, as amended by the Federal Civil Penalties Inflation Adjustment Act Improvements Act, to make annual adjustments to the penalties, based on the prior year’s October Consumer Price Index data from the Bureau of Labor Statistics, and as interpreted and determined by the Office of Management and Budget. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-07-13/ pdf/2026-14084.pdf. Federal Register, Vol. 91, No. 132, 07/13/2026, 43023-43024.

Agencies Seek Comment on Revisions to Regulation O. The Board of Governors of the Federal Reserve System (FRB) seeks comment regarding proposed amendments to Regulation O, which governs loans by member banks to their insiders and insiders of their affiliates. The proposed amendments would update and modernize the regulation, increase transparency by clarifying requirements and incorporating existing interpretations, and promote efficiency by reducing regulatory burden. The proposed amendments also would incorporate existing statutory requirements that are not currently reflected in the regulation. The proposed amendments would also update several outdated dollar-based thresholds and index the thresholds going forward. In addition, the proposed amendments would address the application of Regulation O to member banks that lend to companies that are presumed to be controlled by large asset management companies through passive investment funds. Finally, the proposed amendments would revise and reorganize the regulation to streamline the text. Comments are due 10/05/2026. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-08-04/pdf/202615777.pdf. Federal Register, Vol. 91, No. 148, 08/04/2026, 49526-49568. The Federal Deposit Insurance Corporation (FDIC) seeks comment on a proposed rule to increase quantitative thresholds for certain extensions of credit to insiders of FDIC-supervised institutions, as restricted by the Federal Reserve Act and regulations promulgated thereunder. Specifically, the proposed rule would increase the thresholds for certain extensions of credit to executive officers not otherwise specifically authorized by statute from $100,000 to $400,000; and extensions of credit to insiders requiring prior approval by the board of directors from $500,000 to $2,000,000. The proposed rule would also establish an indexing methodology to periodically update the thresholds over time. Comments are due 10/05/2026. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-08-06/ pdf/2026-15995.pdf. Federal Register, Vol. 91, No. 150, 08/06/2026, 50730-50738.

FRB Proposes to Amend Mutual Holding Company Regulatory Framework. The Board of Governors of the Federal Reserve System (FRB) seeks comment regarding a proposed rule to modernize the regulatory framework applicable to mutual holding companies (MHCs), primarily through proposed revisions to Regulation MM, which governs the formation, operations, activities, and conversion of savings and loan holding companies in mutual form. The proposal would amend Regulation MM by, among other things, eliminating certain dividend waiver requirements, reducing burden associated with conversions from mutual-to-stock form, revising certain post-conversion restrictions, eliminating the requirement that subsidiary holding companies of MHCs obtain federal charters, and revising and clarifying other provisions of the regulation. The proposal also would amend the capital rule (12 CFR part 217) to clarify that certain mutual capital instruments may qualify as regulatory capital and codify model term sheets for mutual capital certificates. Comments are due 10/05/2026. The proposed rule may be viewed at: https:// www.govinfo.gov/content/pkg/FR-2026-08-04/pdf/2026-15774.pdf. Federal Register, Vol. 91, No. 148, 08/04/2026, 49490-49524.

FDIC Updates List of Financial Institutions in Liquidation. The Federal Deposit Insurance Corporation (FDIC) announced it has been appointed the sole receiver for the financial institutions listed in the notices. The appointment is effective as of the “date closed” indicated in the listing. Page 6 | August 2026


Regulatory Spotlight The list (as updated from time to time in the Federal Register) may be relied upon as “of record” notice that FDIC has been appointed receiver for purposes of the statement of policy published in the 07/02/1992, issue of the Federal Register. For further information concerning the identification of any institutions that have been placed in liquidation, use the website, email, or mailing address provided in the notice. The notices may be viewed at: https://www.govinfo.gov/content/pkg/ FR-2026-07-17/pdf/2026-14426.pdf. Federal Register, Vol. 91, No. 136, 07/17/2026, 44848-44849; and https://www. govinfo.gov/content/pkg/FR-2026-07-23/pdf/2026-14900.pdf. Federal Register, Vol. 91, No. 140, 07/23/2026, 46437.

FDIC Seeks Comment on Information Collections. FDIC seeks comment regarding a new information collection titled, Requirements and Standards for FDIC-Supervised Permitted Payment Stablecoin Issuers and Insured Depository Institutions. The Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act) establishes a regulatory framework for payment stablecoin activities. On 04/10/2026, FDIC proposed a rule that would add Part 350 to Title 12 of the Code of Federal Regulation (CFR) and implement certain requirements of the Act. Proposed section 350.7 would, among other things, require permitted payment stablecoin issuers to provide confidential weekly reports and quarterly reports to FDIC as further described in the notice. Comments are due 09/18/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-202607-20/pdf/2026-14589.pdf. Federal Register, Vol. 91, No. 137, 07/20/2026, 45274-45277. FDIC seeks comment regarding an information collection titled, Summary of Deposits. The collection is an annual survey of branch office deposits as of June 30 for all FDIC-insured institutions, including insured U.S. branches of foreign banks. The survey data provides a basis for measuring the competitive impact of bank mergers and has additional use in research on banking. Comments are due 09/21/2026. The notice may be viewed at: https://www.govinfo.gov/content/ pkg/FR-2026-07-22/pdf/2026-14821.pdf. Federal Register, Vol. 91, No. 139, 07/22/2026, 46118-46119. FDIC seeks comment regarding an information collection titled, Regulatory Capital Rules. The collection comprises the recordkeeping, reporting, and disclosure requirements associated with minimum capital requirements and overall capital adequacy standards for insured state nonmember banks, state savings associations, and certain subsidiaries of those entities. The data is used by FDIC to evaluate capital before approving various applications by insured depository institutions, to evaluate capital as an essential component in determining safety and soundness, and to determine whether an institution is subject to prompt corrective action provisions. Comments are due 08/24/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-07-23/pdf/2026-14899.pdf. Federal Register, Vol. 91, No. 140, 07/23/2026, 46437-46439. FDIC seeks comment regarding three information collections, Certified Statement for Quarterly Deposit Insurance Assessment; Foreign Banking and Investment by Insured State Nonmember Banks; and Interagency Guidance on Sound Incentive Compensation Policies. The information collected is used as described in the notice. Comments are due 09/08/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-08-06/pdf/2026-15988.pdf. Federal Register, Vol. 91, No. 150, 08/06/2026, 50735-50737. FDIC seeks comment regarding an information collection titled, Real Estate Lending Standards. Section 1828(o) of the Federal Deposit Insurance Act requires each federal banking agency to adopt uniform regulations prescribing real estate lending standards. Part 365 of FDIC rules and regulations, which implements section 1828(o), requires institutions to have real estate lending policies that include the information as outlined in the notice. Comments are due 10/05/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-08-06/pdf/2026-15992.pdf. Federal Register, Vol. 91, No. 150, 08/06/2026, 50737-50738.

OCC Proposes Changes to Rules on Information Disclosure. The Office of the Comptroller of the Currency (OCC) issued a proposed rule to change its rules on information disclosure. The proposed rule would clarify the process for obtaining OCC approval to disclose non-public OCC information and allow for the disclosure of confidential supervisory information without OCC approval in certain circumstances. The proposed rule also refines OCC’s process for requesting records under the Freedom of Information Act (FOIA), amends the rules to provide for expedited process of FOIA requests, and makes other structural and conforming changes. Comments are due 10/05/2026. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-202608-05/pdf/2026-15867.pdf. Federal Register, Vol. 91, No. 149, 08/05/2026, 50610-50642.

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Regulatory Spotlight OCC Seeks Comment on Information Collections. OCC seeks comment regarding an information collection titled, Securities Offering Disclosure Rules. Twelve CFR part 16 governs the offer and sale of securities issued by national banks and Federal savings associations. The requirements in part 16 enable OCC to perform its responsibility to ensure that the investing public has information about the condition of the institution, the reasons for raising new capital, and the terms of the offering. Part 16 requires that securities offering disclosures of national banks and Federal savings associations be generally consistent with similar Securities Exchange Commission (SEC) disclosure requirements. The principal collections of information under part 16 are described in the notice. Comments are due 08/24/2026. The notice may be viewed at: https://www.govinfo.gov/content/ pkg/FR-2026-07-24/pdf/2026-14973.pdf. Federal Register, Vol. 91, No. 141, 07/24/2026, 46828-46830. OCC seeks comment regarding a new information collection titled, Applications for Licensing or Registration to Issue Payment Stablecoins Under the GENIUS Act. The Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act) sets forth requirements for entities seeking to issue payment stablecoins in the United States, including the process by which entities may seek OCC approval to become a permitted payment stablecoin issuer. Comments are due 09/25/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-07-27/pdf/2026-15088. pdf. Federal Register, Vol. 91, No. 142, 07/27/2026, 47032-47033.

HUD Withdraws OGC Guidance Documents. The Department of Housing and Urban Development (HUD) announced that the Office of General Counsel (OGC) has withdrawn the guidance documents identified in the notice. The listed documents have been removed from active use and should not be relied upon as authoritative. Any handbooks and internal training materials that reference the guidance documents should be revised accordingly. New internal and external guidance will be issued where necessary and appropriate. The withdrawal is effective 09/25/2025. The notice may be viewed at: https://www.govinfo.gov/content/pkg/ FR-2026-07-17/pdf/2026-14432.pdf. Federal Register, Vol. 91, No. 136, 07/17/2026, 44867-44868. nt.

HUD Proposes to Remove Disparate-Impact Liability Provisions From Title VI Regulations. HUD published a proposed rule in January of 2026 to remove its disparate-impact regulations and leave interpretation of disparate-impact liability under the Fair Housing Act to the courts. HUD issued a supplemental proposed rule to continue its efforts to remove or revise regulations that prohibit conduct having a disparate impact without evidence of discriminatory intent. Through the supplemental proposed rule, HUD proposes to remove provisions in Title VI implementing regulations that impose disparate-impact liability on recipients of HUD Federal financial assistance. If finalized, the supplemental proposed rule would improve consistency within HUD’s regulations and between its regulations and Title VI regulations recently revised by Department of Justice. The supplemental proposed rule reopens the comment period of the January 2026 proposed rule on disparate-impact liability. Comments are due 10/09/2026. The supplemental proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-08-10/pdf/202616228.pdf. Federal Register, Vol. 91, No. 151, 08/10/2026, 51416-51421.

FEMA Issues Final Changes in Flood Hazard Determinations. The Federal Emergency Management Agency (FEMA) made new or modified Base (1-percent annual chance) Flood Elevations (BFEs), base flood depths, Special Flood Hazard Area (SFHA) boundaries or zone designations, and/or regulatory floodways (hereinafter referred to as flood hazard determinations) as shown on the indicated Letter of Map Revision (LOMR) final for communities in Minnesota and Wisconsin, as listed in the table in the notice. Each LOMR revises the Flood Insurance Rate Maps (FIRMs), and in some cases the Flood Insurance Study (FIS) reports, currently in effect for the listed communities. Each LOMR was finalized as indicated in the table in the notice. The final notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-08-06/pdf/2026-15944.pdf. Federal Register, Vol. 91, No. 150, 08/06/2026, 50869-50873. New or modified Base (1-percent annual chance) Flood Elevations (BFEs), base flood depths, Special Flood Hazard Area (SFHA) boundaries or zone designations, and/or regulatory floodways (hereinafter referred to as flood hazard determinations) as shown on the indicated Letter of Map Revision (LOMR) have been made final for communities in Iowa, Michigan, and Wisconsin, as listed in the table in the notice. Each LOMR revises the Flood Insurance Rate Maps (FIRMs), and in some cases the Flood Insurance Study (FIS) reports, currently in effect for the listed communities. Page 8 | August 2026


Regulatory Spotlight Each LOMR was finalized as indicated in the table in the notice. The final notice may be viewed at: https://www.govinfo. gov/content/pkg/FR-2026-08-06/pdf/2026-15946.pdf. Federal Register, Vol. 91, No. 150, 08/06/2026, 50879-50882.

FEMA Issues Proposed Flood Hazard Determinations. Comments are requested regarding proposed flood hazard determinations, which may include additions or modifications of any Base Flood Elevation (BFE), base flood depth, Special Flood Hazard Area (SFHA) boundary or zone designation, or regulatory floodway on the Flood Insurance Rate Maps (FIRMs), and where applicable, in the supporting Flood Insurance Study (FIS) reports for communities in Michigan and Wisconsin, as listed in the table in the notice. The FIRM and FIS report are the basis of the floodplain management measures that the community is required either to adopt or to show evidence of having in effect in order to qualify or remain qualified for participation in the National Flood Insurance Program (NFIP). Comments are due 11/04/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR2026-08-06/pdf/2026-15938.pdf. Federal Register, Vol. 91, No. 180, 08/06/2026, 50885-50888.

FEMA Seeks Comment on Application for CDL Program. FEMA seeks comment regarding an information collection titled, Application for Community Disaster Loan (CDL) Program. The loan package for the CDL Program provides local governments that have suffered substantial loss of tax or other revenues as a result of a major disaster, the opportunity to obtain financial assistance in order to perform their governmental functions. The loan must be justified on the basis of need and disaster-related expenses. Comments are due 10/05/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-08-04/pdf/2026-15783. pdf. Federal Register, Vol. 91, No. 148, 08/04/2026, 49435-49436.

IRS Issues Final Rule on Backup Withholding on Third Party Network Transactions. The Internal Revenue Service (IRS) issued a final rule governing backup withholding on reportable payments with respect to third party network transactions. The final rule reflects recent changes to the statutory law that affect the backup withholding requirements for third party settlement organizations who make payments in settlement of third party network transactions. The final rule is effective 08/10/2026. See the final rule for applicability dates. The final rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-08-10/pdf/2026-16269.pdf. Federal Register, Vol. 91, No. 152, 08/10/2026, 51391-51395.

IRS Seeks Comment on Information Collections. IRS seeks comment regarding an information collection titled, Withholding and Information Reporting for Transfers of Partnership Interests. The collection of information relates to regulations under Internal Revenue Code section 1446(f) governing withholding and information reporting for certain transfers of partnership interests. The regulations require certifications, notifications, partnership statements, and related recordkeeping by transferors, transferees, partnerships, brokers, and other affected parties. The information is used to administer the statutory withholding and reporting requirements, determine whether exceptions or adjustments to withholding apply, and ensure that the proper amount of tax is reported and collected. Comments are due 10/05/2026. The notice may be viewed at: https://www.govinfo.gov/ content/pkg/FR-2026-08-04/pdf/2026-15767.pdf. Federal Register, Vol. 91, No. 148, 08/04/2026, 49488. IRS seeks comment regarding U.S. Trust and Estate Income Tax Returns and Related Forms, Schedules, Attachments, and Published Guidance. The forms, schedules, and attachments are used by trusts and estates to report income tax liability. There have been changes in regulatory guidance related to various forms in the collection. There have been additions and removals of forms included in the collection. Comments are due 10/09/2026. The notice may be viewed at: https://www. govinfo.gov/content/pkg/FR-2026-08-10/pdf/2026-16243.pdf. Federal Register, Vol. 91, No. 152, 08/10/2026, 5153051534. IRS seeks comment regarding U.S. Business Income Tax Returns and Related Forms, Schedules, Attachments, and Published Guidance. The forms, schedules, and attachments are used by businesses to report their income tax liability. There have been changes in regulatory guidance related to various forms in the collection. There have been additions and removals of forms included in the collection. Comments are due 10/09/2026. The notice may be viewed at: https://www. govinfo.gov/content/pkg/FR-2026-08-10/pdf/2026-16262.pdf. Federal Register, Vol. 91, No. 152, 08/10/2026, 5153451543. August 2026 | Page 9


Regulatory Spotlight FHFA Rescinds Affordable Housing Program Q&As. The Federal Housing Finance Agency (FHFA) announced the rescission of its 12/23/1997, Questions and Answers Regarding the Affordable Housing Program,” and its 03/11/1999, Questions and Answers Regarding the Affordable Housing Program Part 2 (collectively, Q&As). As of 07/13/2026, the Q&As are withdrawn. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-07-13/pdf/2026-14037.pdf. Federal Register, Vol. 91, No. 132, 07/13/2026, 42960-42961.

SBA Seeks Comment on Model Form of Limited Partnership Agreement. The Small Business Administration (SBA) seeks comment regarding updates to its Model Form of Limited Partnership Agreement to more closely align with customary provisions generally outlined in private funds, while maintaining regulatory and policy provisions within the model that are necessary to minimize the risk of loss in the Small Business Investment Company (SBIC) program and ensure consistency with SBA’s updated regulations and policies. Comments are due 09/21/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-07-21/pdf/202614696.pdf. Federal Register, Vol. 91, No. 138, 07/21/2026, 45872-45873.

FCA Issues Final Rule on Loan Performance Categories and Financial Reporting. The Farm Credit Administration (FCA) issued a final rule to amend its regulatory high-risk loan performance categories by removing “formally restructured loans,” also known as troubled debt restructurings (TDRs). In 2022, changes in generally accepted accounting principles (GAAP) eliminated the accounting guidance for TDRs, enhanced disclosure requirements for certain loan refinancings and restructurings undertaken when a borrower is experiencing financial difficulty and changed existing vintage year disclosure requirements for public business entities. The final rule removes TDRs from FCA regulatory loan performance categories to reflect changes in GAAP. Because FCA regulations require Farm Credit System (System) institutions to prepare financial statements and reports in accordance with GAAP, retaining TDRs as a regulatory loan performance category is no longer consistent with current accounting standards. In addition to making conforming technical changes, the final rule also makes minor technical and organizational revisions to ensure internal consistency within the regulation. In addition, FCA determined that no regulatory amendments are necessary to implement GAAP’s enhanced disclosure requirements for loan modifications to borrowers experiencing financial difficulty or for amended vintage year disclosures, as existing FCA regulations already require GAAP-compliant financial reporting. The final rule will be effective 30 days after publication in the Federal Register during which either or both Houses of Congress are in session. FCA will publish a document announcing the effective date in the Federal Register. The final rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-07-24/pdf/2026-15027.pdf. Federal Register, Vol. 91, No. 141, 07/24/2026, 46703-46706.

CFTC Issues Final Rule on Margin Requirements for Swap Dealers and Major Swap Participants. The Commodity Futures Trading Commission (CFTC) issued a final rule to amend the margin requirements for uncleared swaps applicable to swap dealers and major swap participants that are not subject to the margin rules of a prudential regulator. The amendment revises the definition of “margin affiliate” to provide that certain collective investment vehicles (investment funds) that receive start-up capital from a sponsor entity (seeded funds) would be deemed not to have any margin affiliates or to constitute margin affiliates of another entity for the purposes of calculating certain thresholds that trigger the requirement to exchange initial margin for uncleared swaps (Seeded Funds Amendment). The Seeded Funds Amendment relieves swap dealers and major swap participants subject to CFTC’s uncleared swaps margin rules from the requirement to post and collect initial margin with certain eligible seeded funds for a period of up to three years from the date on which the eligible seeded fund’s asset manager begins making investments on behalf of the fund. CFTC also eliminated a provision disqualifying securities issued by certain pooled investment funds whose asset managers transfer fund assets through securities lending, securities borrowing, repurchase agreements, reverse repurchase agreements, and similar arrangements from being used as eligible initial margin collateral for uncleared swaps, thereby expanding the scope of assets that qualify as eligible collateral. Additionally, CFTC amended the haircut schedule for eligible margin collateral for uncleared swaps to address the haircuts applicable to money market and similar funds. The final rule is effective 08/17/2026. The final rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-07-17/pdf/202614509.pdf. Federal Register, Vol. 91, No. 136, 07/17/2026, 45134-45163. Page 10 | August 2026


Regulatory Spotlight CFTC Issues Order Sunsetting Certain Large Trader Reporting Requirements for Physical Commodity Swaps. CFTC issued an order regarding the sunset provision of its large trader reporting rules for physical commodity swaps (Part 20). Based on the findings set out in the order, CFTC rendered the routine position-reporting requirements of Part 20 ineffective and unenforceable, while preserving, CFTC’s authority to require the maintenance and production, on special call, of the underlying books, records, and futures-equivalent conversion methods. As a result, clearing organizations, clearing members, and swap dealers will no longer be required to file the daily and event-based position reports currently required under Part 20. The order is effective 07/21/2026. The order may be viewed at: https://www. govinfo.gov/content/pkg/FR-2026-07-21/pdf/2026-14710.pdf. Federal Register, Vol. 91, No. 138, 07/21/2026, 4563845640.

CFTC Issues Proposed Rule on Conflicts and Affiliations. CFTC proposed new rules and amendments to its existing regulations for futures commission merchants (FCMs), swap execution facilities (SEFs), designated contract markets (DCMs), and derivatives clearing organizations (DCOs). The proposed rule addresses requirements relating to financial oversight of FCMs by self-regulatory organizations (SROs) and designated self-regulatory organizations (DSROs), as well as disclosure requirements by FCMs regarding affiliate relationships that an FCM has with a SEF, DCM, or DCO. The proposed rule would also establish requirements, including conflicts of interest rules, to address the registered entities’ relationships with certain affiliates, such as FCM affiliates and affiliated principal trading firms. The proposed rule includes guidance regarding implementation of safeguards to protect impartiality of SEFs, DCMs, and DCOs, including where applicable in their role as SROs or performing SRO functions with respect to certain affiliates. The guidance addresses the sharing of resources including staffing, technology, and office space, and limitations on the sharing of non-public information. Comments are due 10/05/2026. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-08-06/pdf/2026-15948.pdf. Federal Register, Vol. 91, No. 150, 08/06/2026, 50926-50995.

SEC Amends Delegation Authority Rules. The Securities and Exchange Commission (SEC) issued a final rule to amend rules delegating authority to SEC staff to further modernize the rules, better reflect the way SEC conducts business, and to more efficiently use SEC resources. The final rule is effective 07/26/2026. The final rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-07-20/ pdf/2026-14540.pdf. Federal Register, Vol. 91, No. 137, 07/20/2026, 45187-45190.

SEC Proposes Regulation E-Delivery. SEC seeks comment regarding proposed Regulation E-Delivery. The proposed rule sets forth conditions for entities to deliver information to recipients electronically without first obtaining their affirmative consent. The proposed rule further establishes conditions under which SEC would consider delivery requirements under the Federal securities laws to be satisfied by electronic delivery. SEC also proposed rescinding the rule that provides alternative means for registered investment companies to satisfy shareholder report transmission requirements, and to amend rules addressing the dissemination of proxy materials and tender offer materials. Comments are due 09/21/2026. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-07-21/pdf/2026-14679.pdf. Federal Register, Vol. 91, No. 138, 07/21/2026, 45884-45989.

NCUA Rescinds Interpretive Rules and Regulations. The National Credit Union Administration (NCUA) issued a final rule to eliminate segregated deposit and collateral requirements for suretyship and guaranty agreements. By removing the requirements, NCUA authorized federallyinsured credit unions acting as sureties and guarantors to design products that address member needs while maintaining safety and soundness standards. Federal credit unions, and federally-insured, state-chartered credit unions if permitted under state law to act as a surety or guarantor, continue to be subject to other requirements related to the arrangements, including the applicable lending regulations. The final rule is effective 09/08/2026. The final rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-08-06/pdf/2026-16027.pdf. Federal Register, Vol. 91, No. 150, 08/06/2026, 50661-50664. August 2026 | Page 11


Regulatory Spotlight NCUA issued a final rule to remove the regulations related to approval and policies on making loans to other credit unions. While the provision will no longer be codified in regulation, federal credit unions remain subject to statutory requirements related to making loans to credit unions. Federally insured, state-chartered credit unions remain subject to any other applicable NCUA or state law or regulation. The final rule is effective 09/08/2026. The final rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-08-06/pdf/2026-16035.pdf. Federal Register, Vol. 91, No. 150, 08/06/2026, 50664-50666. NCUA rescinded Interpretive Ruling and Policy Statement (IRPS) 08-2. The Chartering and Field of Membership Manual incorporates the current requirements for adding underserved areas, making IRPS 08-2 unnecessary. The final action is effective 09/08/2026. The final action may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-08-06/ pdf/2026-16031.pdf. Federal Register, Vol. 91, No. 150, 08/06/2026, 50666-50669. NCUA rescinded Interpretive Ruling and Policy Statement (IRPS) 06-1. The Chartering and Field of Membership Manual incorporates the current requirements for adding underserved areas, making IRPS 06-1 unnecessary. The final action is effective 09/08/2026. The final action may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-08-06/ pdf/2026-16028.pdf. Federal Register, Vol. 91,No. 150, 08/06/2026, 50669-50672. NCUA rescinded Interpretive Ruling and Policy Statement (IRPS) 10-1. The Chartering and Field of Membership Manual incorporates NCUA’s current chartering requirements for federal credit unions, making IRPS 10-1 unnecessary. The final action is effective 09/08/2026. The final action may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-08-06/ pdf/2026-16024.pdf. Federal Register, Vol. 91, No. 150, 08/06/2026, 50672-50674. NCUA issued a final rule to revise its regulations governing the organization and operation of federal credit unions to eliminate a provision related to credit union service contracts. The final rule is effective 09/08/2026. The final rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-08-06/pdf/2026-16021.pdf. Federal Register, Vol. 91, No. 150, 08/06/2026, 50674-50677. NCUA issued a final rule to remove the regulation regarding third-party servicing of indirect vehicle loans. The final rule will reduce regulatory burden and provide federally-insured credit unions with greater operational flexibility, consistent with a principles-based supervisory approach. The final rule is effective 09/08/2026. The final rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-08-06/pdf/2026-16029.pdf. Federal Register, Vol. 91, No. 150, 08/06/2026, 50677-50680. NCUA issued a final rule to streamline regulations governing the purchase, sale, and pledge of eligible obligations. Specifically, the final rule removes the lists of items that must be addressed in the written policies adopted by a federal credit union. The final rule also removes detailed requirements regarding conflicts of interest and compensation. The final rule is effective 09/08/2026. The final rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-08-06/ pdf/2026-16030.pdf. Federal Register, Vol. 91, No. 150, 08/06/2026, 50680-50684. NCUA rescinded Interpretive Ruling and Policy Statement (IRPS) 11-02, which addresses chartering corporate credit unions, because it is redundant to the Federal Corporate Credit Union Chartering Manual. The final action is effective 09/08/2026. The final action may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-08-06/pdf/2026-16022. pdf. Federal Register, Vol. 91, No. 150, 08/06/2026, 50684-50686. NCUA issued a final rule to amend its regulations that establish the requirements for obtaining and maintaining federal share insurance with the National Credit Union Share Insurance Fund. The provisions apply to all federally-insured credit unions. The final rule is effective 09/08/2026. The final rule may be viewed at: https://www.govinfo.gov/content/pkg/FR2026-08-06/pdf/2026-16023.pdf. Federal Register, Vol. 91, No. 150, 08/06/2026, 50686-50688. NCUA issued a final rule to amend its regulations that establish the requirements for obtaining and maintaining federal share insurance with the National Credit Union Share Insurance Fund. The provisions apply to all federally-insured credit unions. The final rule is effective 09/08/2026. The final rule may be viewed at: https://www.govinfo.gov/content/pkg/FR2026-08-06/pdf/2026-16026.pdf. Federal Register, Vol. 91, No. 150, 08/06/2026, 50688-50691.

Page 12 | August 2026


Regulatory Spotlight NCUA Seeks Comment on Information Collections. NCUA seek comment regarding several information collections, Security Program; 12 CFR part 723, Member Business Loans, Commercial Lending; and Recordkeeping and Disclosure Requirements Associated with Regulations B, E, M, and CC. The information collected is used as described in the notice. Comments are due 08/27/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-07-28/pdf/2026-15196.pdf. Federal Register, Vol. 91, No. 143, 07/28/2026, 47262-47263.

Compliance Notes FinCEN issued an alert, in consultation with the U.S. Department of Education’s (ED) Office of Inspector General and the FBI, urging financial institutions to be vigilant in detecting, identifying, and reporting suspicious activity connected to fraud schemes targeting ED’s Office of Federal Student Aid programs. Fraud rings use stolen and fraudulent identities, as well as other tactics, to enroll in educational institutions and unlawfully acquire funds from Federal student aid programs. FinCEN requests that financial institutions reference the Alert in SAR field 2 (Filing Institution Note to FinCEN) and the narrative by including the key term “FIN-2026-FSAFRAUD” and select SAR field 34(z) (Fraud-Other) and include the term “Federal Student Aid Fraud” in the text box. The alert may be viewed at: https://www.fincen.gov/ system/files/2026-07/FinCEN-Alert-Fraud-Schemes-Targeting-Federal-Student-Aid.pdf Agencies released a revised Community Bank Leverage Ratio (CBLR) compliance guide consistent with the changes made to the framework in the final CBLR final rule published in April 2026. The changes became effective 07/01/2026. The compliance guide may be viewed at: https://www.fdic.gov/news/financial-institution-letters/2026/ community-bank-leverage-ratio-framework-community-bank FDIC announced the launch of a new Office of Supervisory Appeals (OSA) panel comprised of independent officials who will consider and resolve appeals of material supervisory determinations brought before FDIC. OSA is a standalone office within FDIC and replaces the Supervision Appeals Review Committee as the final level of review of material supervisory determinations. The announcement may be viewed at: https://www.fdic.gov/news/pressreleases/2026/fdic-launches-new-office-supervisory-appeals FinCEN has ended its BOI reporting requirements for small business owners. FinCEN’s action removes the requirement for U.S. companies and U.S. persons to report BOI to FinCEN. FinCEN also announced it will delete previously reporting information by U.S. persons, now exempt from the reporting requirements, from the beneficial ownership information database. The change by FinCEN to this BOI report rule does not impact banks’ BOI requirements under the BSA-related customer due diligence (CDD) rule. All current bank BOI responsibilities remain intact. FinCEN’s change only applies to the rule that required business to themselves report BOI information directly to FinCEN. The announcement may be viewed at: https://www.fincen.gov/news/news-releases/fincen-permanently-ends-beneficialownership-reporting-requirements-millions August 2026 | Page 13


Compliance Notes FRB announced it is updating aspects of its Borrower in Custody (BIC) program as part of ongoing discount window modernization. Through the BIC program, eligible institutions may pledge a wide variety of loan types to maximize liquidity while maintaining possession of the collateral. The changes include simplified forms, faster enrollment, automated pledged loan lists, modified maintenance, focused inspections, and centralized resources. The changes are effective 09/08/2026. The announcement may be viewed at: https://www.frbdiscountwindow.org/ articles/2026/07/30/12/47/bic_standards_announcement_20260806 SBA announced that small businesses across the energy production supply chain are now eligible for a new 90% Energy Guarantee through the SBA International Trade Loan (ITL) Program. Established as part of SOP 50 10 8.1, the enhanced guarantee encourages participating lenders to unleash private investment in energy production, distribution, grid modernization, and equipment manufacturing to increase energy output and support lower costs for households and small businesses. Small businesses in the NAICS codes listed in the announcement are eligible for the expanded ITL Loan Program. The announcement may be viewed at: https://legacy.sba.gov/article/2026/08/14/sba-announces-90-loanguarantee-energy-sector IRS issued guidance to simplify and standardize the rollover process by issuing sample forms for direct rollovers to or from a retirement plan, as required under the SECURE 2.0 Act section 324. The sample forms and proposed rollover procedures aim to simplify and standardize the rollover process for both participants and plan sponsors. The guidance applies to rollovers between retirement plans or between a retirement plan and an IRA, but not to IRA-to-IRA transfers. The sample forms are designed to protect participants’ personal identifying information and minimize participants’ burden. Use of the sample forms and proposed procedures is optional for plan sponsors. The guidance and forms may be viewed at: https://www.irs.gov/newsroom/treasury-irs-issue-guidance-on-rollovers-between-retirement-plans-andindividual-retirement-accounts Nacha reports a nearly 30% jump in the number of Same Day ACH payments and a nearly 10% increase in business-to-business payments for second quarter 2026. The activity report may be viewed at: https://www.nacha.org/ news/large-gains-same-day-ach-help-drive-ach-network-second-quarter-2026 FinCEN issued a financial trend analysis which shows that financial institutions flagged nearly $5 billion linked to suspected human smuggling over a three-year period. The report, which analyzed patterns and trends identified in BSA data between 2023 and 2025, identified several consistent indicators, including unverifiable relationships between originators and beneficiaries, transactions sent along common migration routes, and excessive cash activity conducted along the southwest border of the United States. The report may be viewed at: https://www.fincen.gov/news/newsreleases/fincen-analysis-financial-institutions-flagged-nearly-5-billion-linked-suspected OCC released its annual update to the Bank Accounting Advisory Series (BAAS). BAAS contains staff responses to frequently asked questions from the banking industry and bank examiners on a variety of accounting topics and promotes consistent application of accounting standards and regulatory reporting among national banks and federal savings associations. The new edition reflects updates to accounting standards issued by the Financial Accounting Standards Board on topics including purchased loans, government grants, and internal-use software. BAAS does not represent rules or regulations of OCC. It contains OCC Office of the Chief Accountant’s interpretations of generally accepted accounting principles and regulatory guidance based on the facts and circumstances presented. The updated resource may be viewed at: https://occ.gov/news-issuances/news-releases/2026/nr-occ-2026-68.html CFPB announced it will end publication of unverified consumer complaint narratives and visualizations in the Consumer Complaint Database. As CFPB has long acknowledged, the publication in the Database of unverified complaint narratives and associated data visualizations is entirely discretionary. Many years of experience have demonstrated that the utility of such publication is minimal, while often causing confusion and providing misleading data. The announcement may be viewed at: https://www.consumerfinance.gov/about-us/newsroom/the-cfpb-to-cease-discretionary-publicationof-complaint-narratives-and-visualizations/

Page 14 | August 2026


Compliance Notes

The states of California, Connecticut, Maine, Maryland, Massachusetts, Minnesota, Rhode Island, and Vermont joined Oregon and New York in a lawsuit against OCC to block two recent rules designed to establish a uniform federal framework for national banks operating across state lines. https://bankingjournal.aba.com/2026/08/state-coalition-seeksto-block-occ-preemption-of-interest-on-escrow-laws/ Treasury announced guidance addressing employer-sponsored programs for contributions to Trump Accounts, including arrangements that allow employees to make pre-tax contributions to the Trump Accounts of their dependents. The guidance also accommodates employers that have committed to, and those that are interested in, contributing directly to an employee’s dependent’s Trump Account by providing flexible and non-restrictive rules. The guidance may be viewed at: https://home.treasury.gov/news/press-releases/sb0602

August 2026 | Page 15


September

October continued

Principles of Banking 9-10 22-23 9

Fond du Lac - $550/attendee Madison - $550/attendee

9/1011/6

NEW! Digital Innovation Development Program

15-16

Consumer Lending Boot Camp

Six-part virtual series – $1,000/attendee Madison – $550/attendee

Milford Hills Outing Johnson Creek

9/1711/6

Credit Analyst Development Program

24

Wisconsin Bankers Foundation Gala Branch Manager Boot Camp: Session I Four-part series, virtual half days – $900/attendee

28

Innovation Showcase Wisconsin Dells – multiple registration options

29-30

27-29

Bank Trainers Conference & Expo

Bank Technology & Security Summit Wisconsin Dells – multiple registration options

9/3010/1

Personal Banker School

ongoing

Fraud On-Demand Video Series

Wisconsin Dells - $550/attendee

Supervisor Boot Camp

Madison or Virtual - $275/attendee 28

Advanced Commercial Lending Boot Camp Online Workshop: C&I Lending in Today’s Competitive Environment Virtual full day – $275/attendee

15

FDIC Bank Directors Summit Madison - $275/attendee

20

Online Workshop: Wowing the Client Virtual half-day – $300/attendee

TBD

Hot Topics in Commercial & Agricultural Lending Webinar Series Multi-part webinar series

November 4

BOLT Winter Leadership Summit Wisconsin Dells – $200/attendee

17

Compliance Forum: Session II Wisconsin Dells – annual membership/pricing varies

18-19

FLEX Retail & Marketing Summit Wisconsin Dells – multiple registration options

19

Branch Manager Boot Camp: Session III Four-part series, virtual half days – $900/attendee

2

Madison – $550/attendee Madison – $550/attendee

14

Regulation E Workshop

December

October 13-14

Deposit Compliance School Madison or virtual - $895/attendee

29

Four-part video series – $795/bank

7-8

Eight-part webinar series – $1,000/attendee Nashville, TN

27-29

Six-part virtual series – $2,750/attendee Madison – Individual or Table Tickets Available

24

Understanding Bank Performance Virtual Series

Strategic Management Summit Stevens Point – $275/attendee

16

10/2211/13

Community Bankers for Compliance – Session IV

Online Workshop: CRE Lending in Today’s Environment Virtual full day – $275/attendee

17

Branch Manager Boot Camp: Session IV Four-part series, virtual half days – $900/attendee

KEY: Color-Coded Event Descriptions Conferences/Summits – One or more days, based on hot topics, industry news and best practices, scheduled time for peer networking.

Virtual half-day – annual membership/pricing varies

Schools/Boot Camps – Focused on a particular area of banking, allowing

20

IRA Essentials Workshop

for a deep dive into that focused area over the course of two to six days.

21

Advanced IRA Workshop

Madison or Virtual - $275/attendee Madison or Virtual - $275/attendee

22

Workshops/Seminars – One-day programs focused on a specific topic or area of banking.

BSA/AML Workshop

WBA-Hosted Webinars

Madison or Virtual - $275/attendee

Other Events

www.wisbank.com | 608-441-1252 | wbaeducation@wisbank.com

Page 16 | August 2026


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