December 2025 Compliance Journal

Compliance Journal December 2025

Special Focus IRS Interim Guidance on IRC 139L Regarding Interest on Loans Secured by Rural or Agricultural Real Property The Internal Revenue Service (IRS) has recently issued interim guidance regarding the new exclusion for interest on loans secured by rural or agricultural real property under Internal Revenue Code (IRC) section 139L. Section 139L was added to the IRC by the One, Big, Beautiful Bill Act (OBBBA), effective July 4, 2025. IRS plans to issue a proposed rule similar to the interim guidance and seeks information regarding its approach to the new section.

The purpose of this article is to identify who is a qualified lender, what is considered a qualified real estate loan, and describe other key definitions under the interim guidance to help bankers determine what loans to identify for tracking under the new exclusion. Banks are reminded to work closely with their accounting resources to further identify how the new exclusion effects the bank’s financial reporting, to consider the impact on interest expense deductions, and other accounting-related matters or documentation and recordkeeping best practices.

New IRC Exclusion As stated above, OBBBA created a new IRC exclusion, ILC 139L. IRC Section 139L(a) excludes from gross income twenty-five (25) percent of the interest received by a qualified lender on any qualified real estate loan and includes in gross income seventy-five (75) percent of the interest received on a qualified real estate loan in the taxable year.

A qualified lender is not required to have been the original holder of a qualified real estate loan on the issue date of the qualified real estate loan in order to exclude interest income under section 139L(a). For example, a qualified lender may include a subsequent holder of a qualified real estate loan, if the subsequent holder is a qualified lender.

Definitions Qualified Lender For purposes of the interim guidance, the term “qualified lender” includes an FDIC-insured bank or savings association and any state- or federally-regulated insurance company. The term also means any entity wholly owned, directly or indirectly, by a bank or insurance holding company if the entity is organized, incorporated, or established under the laws of the U.S. or any State, and the principal place of business of such entity is in the U.S., including any territory of the U.S. Qualified Real Estate Loan The interim guidance provides that the term “qualified real estate loan” means a loan secured by rural or agricultural real estate, or a leasehold mortgage (with a status as a lien) on rural or agricultural real estate, that is made to a U.S. person, and made after July 4, 2025. The determination of whether a property securing the loan is rural or agricultural real estate is made as of the time the interest income on the loan is accrued.

For purposes of determining whether a loan was made before (pre-enactment loan) or after July 4, 2025, if the proceeds of a loan (new loan) are used in part to refinance a pre-enactment loan and in part for other purposes, the portion of the new loan used to refinance the pre-enactment loan is treated as made on or before July 4, 2025. The amount of the new loan that may be treated as a qualified real estate loan is limited to the portion of the new loan that exceeds the outstanding balance of the pre-enactment loan as of the date of the refinancing. In such case, a qualified lender must allocate the principal of the new loan between amounts used to refinance any pre-enactment loan and amounts

Special Focus borrowed for other purposes accordingly. Any payments of interest or principal on the new loan are allocated to the portion of the new loan that is a pre-enactment loan and the portion that may be a qualified real estate loan on a pro rata basis.

A significant modification of a pre-enactment loan is treated as a refinancing of the pre-enactment loan. The interim guidance refers to Treasury regulation section 1.1101-3 regarding what is to be considered a significant modification.

Furthermore, a borrowing after the date of enactment that is added to the principal amount of any pre-enactment loan or a borrowing after the date of enactment pursuant to a line of credit or similar agreement entered into on or before the date of enactment that allows the borrower to borrow periodically under the agreement (post-enactment amount), is not treated as a pre-enactment loan to the extent of the post-enactment amount. For purposes of this condition, the post-enactment amount does not include any amount that is used to refinance a pre-enactment loan.

In cases where the outstanding principal includes both a pre-enactment loan and a postenactment amount, a qualified lender must allocate the principal amount between the preenactment loan and the post-enactment amount and must allocate payments of principal or interest on a pro rata basis.

Rural or Agricultural Real Estate The interim guidance defines the term “rural or agricultural real estate” to mean any real property that is substantially used for the production of one or more agricultural products; any real property which is substantially used in the trade or business of fishing or seafood processing; and any aquaculture facility. The term does not include any property which is not located in a state or possession of the U.S. The term “aquaculture facility” means any land, structure, or other appurtenance that is used for aquaculture (including any hatchery, rearing pond, raceway, pen, or incubator).

The presence of a residence on qualified or agricultural property, or intermittent periods when such property is not used for the production of one or more agricultural products due to seasonality, fallowing, or similar circumstances, does not prevent the property from being qualified rural or agricultural property as long as the property satisfies the substantial use requirement. However, by contrast, property with only minimal or incidental agricultural activity generally would not be considered to be used for the production of one or more agricultural products, including for the purpose of a small personal garden, backyard beekeeping, and keeping chickens to produce eggs for household use.

Interest Received The term “interest received” means the interest, including amounts treated as interest under the IRC, that is includible in gross income by a qualified lender. For purposes of the preceding sentence, the amount of interest includible in gross income by a qualified lender is determined without regard to section 139L, and the time at which interest is includible in gross income is determined under the qualified lender’s overall method of accounting (for example, the cash receipts and disbursements method of accounting or an accrual method of accounting) or, if applicable, under a special method of accounting (for example, section 1272 for original issue discount).

Determining Whether a Loan is Secured by Qualified Rural or Agricultural Property A qualified real estate loan is secured by qualified rural or agricultural property only if, at the time interest income on such loan accrues, the qualified lender holds a valid and enforceable security interest with respect to the qualified rural or agricultural property under applicable law.

Page 2 | December 2025

December 2025 Volume 31, Number 7 Wisconsin Bankers Association 4721 South Biltmore Lane, P.O. Box 8880, Madison, Wisconsin, 53708-8880 Senior Writers Heather MacKinnon Scott Birrenkott Editor Ramon Morales Layout Christian Heo

Copyright ©2025 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 As a general rule under the interim guidance, the amount of a loan that is a qualified real estate loan is limited to the fair market value (FMV) of the qualified rural or agricultural property securing the loan, determined as of the issue date of the loan. If the amount of the loan, that is, the issue price of the loan, exceeds the FMV of the qualified rural or agricultural property securing the loan, determined as of the issue date of the loan, only the portion of the loan that does not exceed such value is a qualified real estate loan. For example, if, on the issue date of a loan, the loan is secured by qualified rural or agricultural property with a FMV of $10,000 and the amount of the loan is $100,000, then only $10,000 of the loan is a qualified real estate loan.

A qualified lender that is a subsequent holder makes the determination of whether the loan is secured by qualified rural or agricultural property either based on the FMV of the qualified rural or agricultural property securing the loan and the issue price of the loan on the issue date, or based on the FMV of such property and the adjusted issue price of the loan on the date the qualified lender acquires the loan.

IRS has created a safe harbor for determining whether a loan is secured by qualified rural or agricultural property.

Notwithstanding the general determination outlined above, a qualified lender may treat a loan as fully secured by qualified rural or agricultural property for purposes of the interim guidance if: (1) the terms of the loan provide the qualified lender holds a valid and enforceable security interest with respect to the qualified rural or agricultural property under applicable law; and (2) the FMV of the qualified rural or agricultural property securing the loan is at least 80 percent of the issue price of the loan on the issue date. For example, if, on the issue date of a loan, the loan is secured by qualified rural or agricultural property with a FMV of $85,000 and the issue price of the loan is $100,000, then the entire loan is treated as a qualified real estate loan.

A qualified lender that is a subsequent holder may apply the safe harbor either based on the FMV of the qualified rural or agricultural property securing the loan and the issue price of the loan on the issue date, or based on the FMV of such property and the adjusted issue price of the loan on the date the qualified lender acquires the loan.

To determine the FMV of the property, the qualified lender may use any commercially reasonable valuation method which includes a method the qualified lender uses in the ordinary course of its trade or business for valuing property that secures loans. A commercially reasonable valuation method may take into account expectations regarding the rural or agricultural real estate’s production of income from the activities conducted on such real estate. For example, a qualified lender’s commercially reasonable valuation method may take into account the value of crops on or the projected income from harvesting crops on the rural or agricultural real estate securing the loan.

The interim guidance also sets forth that for purposes of a qualified real estate loan, a qualified lender may, subject to the limitation in the following sentence, add to the FMV of the rural or agricultural real estate the FMV of any personal property used in the course of the activities conducted on such real estate, such as farm equipment and machinery or livestock. A qualified lender may include the value of personal property in such determination only if the qualified lender holds a valid and enforceable security interest with respect to such personal property under applicable law, and only if the relevant loan is secured to a substantial extent by rural or agricultural real estate. For example, if real property substantially used for the production of corn is valued at $500,000, and farm equipment and machinery used for the production of corn on such real property is valued at $50,000, the total value that may be used to determine the FMV of the qualified rural and agricultural property for purposes of determining whether a loan is secured by qualified rural or agricultural property and the safe harbor would be $550,000.

Subsequent FMV testing is not required so long as the qualified real estate loan continues to be secured by the qualified rural or agricultural property and there is not a subsequent significant modification of such loan. The borrower’s use of the loan proceeds does not affect whether a loan may be treated as a qualified real estate loan.

Reasonable Belief Standard If a qualified lender initially determined a loan was secured by qualified rural or agricultural property under the interim guidance and reasonably believes in good faith that the loan continues to be so secured, then the qualified lender may rely on that initial determination at the time interest income on such loan accrues for purposes of a qualified real estate loan.

A reasonable, good-faith belief exists only if the qualified lender reasonably believes in good faith both that the security December 2025 | Page 3

Special Focus interest remains in place and that the rural or agricultural real estate continues to be used in a manner that qualifies it as rural or agricultural real estate. A qualified lender may base the reasonable, good-faith belief on covenants or other certifications made by the borrower of the loan or other parties that have actual knowledge or reason to know that the loan is secured by qualified rural or agricultural property.

If, despite the qualified lender’s reasonable, good-faith belief, the qualified lender, on a later date, learns or has reason to believe that a loan is no longer secured by qualified rural or agricultural property, the loan will lose its status as a qualified real estate loan under section 139L on that date. In such an instance, the loan will not loss its status if within 90 days following the date on which the qualified lender learns or has reason to believe that the loan is not secured by qualified rural or agricultural property, the qualified lender, borrower, or other party causes the loan to be secured by qualified rural or agricultural property.

Forthcoming Proposed Rule As mentioned initially, IRS will be issuing a proposed rule regarding IRC 139L. It is anticipated the proposed rule will include provisions consistent with the interim guidance. Once finalized, the rules will apply for taxable years beginning after the final rule is published in the Federal Register. Banks may rely on the interim guidance for loans made after July 4, 2025, and on or before the date that is thirty (30) days after the forthcoming proposed rule is published in the Federal Register.

The interim guidance includes several questions for which IRS seeks comments and information. The questions include the meaning of the terms included in this article; if factors should be considered to address whether property is substantially used for the production of one or more agricultural products, or in the trade or business of fishing or seafood processing; and for other factors such as mixed-use property or changes in use of real property. Comments regarding the interim guidance are due January 20, 2026.

Conclusion In late November, IRS issued interim guidance regarding the new exclusion for interest on loans secured by rural or agricultural real property under IRC section 139L to help lenders identify what loans may qualify for the new exclusion. The guidance also creates a safe harbor for determining the FMV of property and how to treat refinancings, and additional borrowings made to the principal amount of any pre-enactment loan.

WBA will be filing comments with the IRS regarding its interim guidance. If you have questions or wish to discuss comments or concerns regarding the guidance, please be sure to contact WBA Legal at wbalegal@wisbank.com or at 608-441-1200. WBA will be filing comments by January 20, 2026.

The Internal Revenue Code Section 139L may be viewed at: https://uscode.house.gov/browse/prelim@title26/subtitleA/chapter1/ subchapterB/part3&edition=prelim The IRS Interim Guidance may be viewed at: https://www.irs.gov/pub/irs-drop/n-25-71.pdf

Privacy Considerations When Banks Suspect Elder Financial Abuse Elder financial abuse continues to be a significant issue in Wisconsin. In 2023, Dane County Adult Protective Services investigated 408 reports of elder abuse. Financial exploitation was the most common category, with losses exceeding $1 million.

Based on conversations WBA has had with law enforcement and state officials, the true scope is likely much larger, as many incidents go unreported.

Banks are often the first line of defense against elder financial abuse. Because they regularly observe customer behavior and transaction patterns, Wisconsin banks are uniquely positioned to spot activity that may suggest financial exploitation. At the same time, banks frequently express uncertainty about how to balance their obligation to protect customers with their duty to comply with privacy laws and regulatory expectations. The Gramm Leach Bliley Act (GLBA), implemented through Regulation P, establishes strict privacy rules, while Wisconsin statutes create avenues for reporting suspected elder financial abuse. Many banks have questions regarding how these frameworks work together in practice.

Page 4 | December 2025

Special Focus This article provides an overview of privacy laws, the relevant exceptions, how Wisconsin’s reporting structure for suspected elder financial abuse fits within those requirements, as well as some practical considerations.

Privacy Requirements GLBA establishes the primary federal privacy framework that banks must follow when handling customer financial information. It requires banks to safeguard nonpublic personal information, limit its disclosure, and provide clear privacy notices that describe the bank’s information sharing practices. Regulation P implements these requirements.1 Generally speaking, GLBA restricts disclosure of nonpublic personal information to nonaffiliated third parties unless a specific exception applies. These exceptions are found in 15 U.S.C. § 6802(e) and implemented through Regulation P at 12 C.F.R. § 1016.15. Together, these provisions recognize that protecting customer information must be balanced with situations where disclosure is necessary for legal compliance or customer protection.

Several of GLBA’s exceptions directly support the ability of banks to report suspected elder financial exploitation.

GLBA permits disclosure of information that is necessary to protect against or prevent actual or potential fraud, unauthorized transactions, claims, or other liability.2 GLBA also allows disclosure to comply with federal, state, or local laws, regulations, or other legal requirements, including Wisconsin’s adult protective services reporting laws.3 In addition, GLBA authorizes disclosures to law enforcement or other government authorities for investigations related to public safety, which encompasses county elder adult-at-risk and adult-at-risk agencies acting within their investigative authority.4 These exceptions provide the federal foundation that allows banks to cooperate with county agencies and law enforcement when exploitation is suspected while remaining compliant with federal privacy law.

Additionally, in 2013, the agencies issued guidance on privacy laws and reporting financial abuse of older adults.

The guidance acknowledges that various federal and state authorities either require or encourage reporting of this type of information to the appropriate agency. It also clarifies that reporting suspected financial abuse of older adults to appropriate local, state, or federal agencies does not, in general, violate the privacy provisions of the GLBA or its implementing regulations. A link to this guidance is included at the end of the article.

Wisconsin Elder Financial Abuse Reporting In 2005, Wisconsin significantly modernized its system for responding to elder abuse and financial exploitation. A new law revised Wisconsin’s elder abuse statute in Wis. Stat. § 46.90 and created a parallel framework in Wis. Stat. § 55.043 for “adults at risk.” Counties must designate an elder-adult-at-risk agency, and those agencies are required to establish an abuse reporting system and enter into memoranda of understanding (MOU) with county departments and other public or private agencies that participate in the system. The MOU must, at a minimum, identify which agencies are responsible for investigating reports of abuse, financial exploitation, neglect, or self-neglect and which entities will provide direct services to affected adults.

Under current law, any person, including bank personnel, may report suspected abuse, financial exploitation, neglect, or self-neglect of an elder adult at risk.5 Reports may be made to the county elder-adult-at-risk (or adult-at-risk agency), the county department of human or social services, state or local law enforcement, the Department of Health Services, or the Board on Aging and Long-Term Care as authorized.6 Certain professionals are mandatory reporters, but bank employees are not included in the list of mandated reporters.7 Both statutes provide strong protections for voluntary reporters.

Anyone who reports in good faith is immune from civil and criminal liability and from findings of unprofessional conduct, and retaliation against reporters is prohibited.8 1 Regulation P also requires certain notices, opt-out provisions, among other requirements. These requirements will not be discussed in this article which will instead focus on the more general expectation of privacy requirements and exceptions.

2 15 U.S.C. § 6802(e)(3)(B) and 12 C.F.R. § 1016.15(a)(2)(ii).

3 15 U.S.C. § 6802(e)(8) and 12 C.F.R. § 1016.15(a)(7)(i).

4 15 U.S.C. § 6802(e)(5) and 12 C.F.R. § 1016.15(a)(7)(ii) 5 Wis. Stat. § 46.90(4)(ar) and Wis. Stat. § 55.043(1m)(br).

6 Wis. Stat. § 46.90(4)(ac) and Wis. Stat. § 55.043(1m)(br).

7 Wis. Stat. § 46.90(4)(ab) and Wis. Stat. § 55.043(1m)(a).

8 Wis. Stat. § 46.90(4)(b)–(c), (e) and Wis. Stat. § 55.043(1m)(c)–(d), (f ).

December 2025 | Page 5

Special Focus For investigations of suspected financial exploitation, the elder-adult-at-risk and adult-at-risk agencies are expressly authorized to obtain and review a customer’s financial records. Wisconsin law requires banks and other financial record holders to release financial records of an elder adult at risk or adult at risk without the customer’s informed consent when the release is to the elder-adult-at-risk or adult-at-risk agency or another investigative agency acting under Wis. Stat. § 46.90 or § 55.043, or when release is directed by a lawful court order. In addition, the statutes permit the financial record holder to initiate contact and release financial record information to the elder-adult-at-risk or adult-at-risk agency without first receiving a formal request.

Federal regulators have confirmed that this Wisconsin reporting framework is compatible with GLBA privacy requirements.

Wisconsin’s New “Trusted Contacts” Law Wisconsin recently created an additional tool to help financial service providers address potential financial exploitation.

Enacted in 2024 and codified in Wis. Stat. § 224.45, the new law establishes a process for identifying “vulnerable adults” and creates a mechanism for customers to designate a List of Authorized Contacts. A “vulnerable adult” includes any adult at risk under Wis. Stat. § 55.01(1e) as well as any individual age 65 or older. This definition is different, and broader in certain respects, than the elder adult at risk standard in Wis. Stat. § 46.90, which applies beginning at age 60.

Importantly, § 224.45 does not change or limit the long-standing voluntary reporting procedures under § 46.90. Instead, the new law provides an additional avenue for early intervention.

Under § 224.45, financial service providers may offer a vulnerable adult the option to submit and update a list of individuals the provider is authorized to contact when the provider has reasonable cause to suspect that the customer is a victim or target of financial exploitation. The bank may rely on information provided by the customer when creating or updating this list. If concerns arise, the bank may convey its suspicion to any listed contact, a co-owner or authorized signer on the account, a beneficiary, or certain known family members, provided the individual contacted is not a suspect.

The provider may also choose not to contact someone on the list.

When a bank communicates with an authorized contact under this law, it may limit the disclosure to a general statement that it has reasonable cause to suspect financial exploitation. The bank is not required to share details of the customer’s financial records or confidential information. As always, the bank should consider whether the facts also trigger reporting obligations under the Bank Secrecy Act (BSA) or internal escalation procedures.

The law also provides strong protections for banks and employees who act in good faith. A financial service provider that makes or declines to make a contact under § 224.45 based on reasonable suspicion is immune from civil, criminal, and administrative liability.

Practical Considerations The above frameworks create several practical considerations for banks facing situations of potential elder financial abuse. When a bank has reason to suspect financial exploitation, it is permitted to act. Both federal and Wisconsin law give banks authority to raise concerns, share relevant information with the appropriate county agency, and take reasonable steps to prevent harm. Absolute certainty is not required. A report may be made based on reasonable suspicion supported by observable facts, and in many situations, bank personnel may be the first or only individuals positioned to identify warning signs.

Privacy requirements should not be viewed as a barrier to protecting vulnerable customers. GLBA and Regulation P contain specific exceptions that allow disclosures related to fraud, unauthorized transactions, safety concerns, and compliance with state reporting laws. Wisconsin’s elder abuse statutes not only permit banks to report suspected exploitation, they also provide legal protections for employees who report in good faith. These frameworks operate together to ensure that reporting concerns to county agencies is both permissible and aligned with a bank’s responsibility to safeguard its customers.

The new Wis. Stat. § 224.45 provides banks with an additional early intervention tool. Banks may choose to offer customers the option to designate a List of Authorized Contacts and may notify those contacts when the bank has reasonable cause to suspect that a vulnerable adult is being targeted for financial exploitation. This process can Page 6 | December 2025

Special Focus be particularly valuable in situations where a trusted family member or contact can help verify concerns, clarify the customer’s intentions, or assist the customer before harm occurs. Banks should evaluate when and how they will offer this option to customers, how lists will be maintained, and how staff will be trained to identify when contacting an authorized individual is appropriate.

When a county elder-adult-at-risk or adult-at-risk agency initiates an investigation, banks must provide financial records relevant to the inquiry. These disclosures do not violate federal privacy rules and may be made even if the customer has not provided consent. Banks may also initiate contact with a county agency when they believe exploitation is occurring.

Early communication often allows county agencies to intervene sooner and provide needed support to vulnerable customers.

Internal procedures remain essential for guiding staff in identifying and responding to suspected financial exploitation.

Banks should ensure that employees understand red flags, escalation pathways, and how the Wisconsin laws discussed above interact with existing reporting options. Procedures should also address coordination with bank’s BSA program, including when a suspicious activity report (SAR) or other action may be appropriate, and how information should be documented and communicated internally.

For example, banks should ensure that frontline staff receive training on how to spot financial exploitation and also know who within a management team suspected financial exploitation should be reported to for further investigation. Branch managers, compliance officers, and other staff investigating reports from frontline staff should be aware of reporting duties and opportunities discussed above to further weigh bank action and next steps. Bank’s BSA staff should also be involved to further identify whether a SAR needs to be filed, whether other action is appropriate, and how best to document bank’s decisions and actions. Similarly, for banks that have implemented a process for the designation of a List of Authorized Contacts under Wis. Stat. § 224.45, bank staff should know the process to obtain a designation, how to check whether there is a designation on file, and the process for determining who to contact and when to act.

While Wisconsin’s elder abuse reporting system only requires certain individuals and agencies to enter into an MOU, banks may still consider utilizing one as a matter of policy. While not required to report, an MOU could still be used to clarify communication expectations, establish clear points of contact, streamline the process when an investigation arises, and help ensure adherence to regulatory expectations. Having this framework in place often makes it easier for staff to know how and when to report concerns and can improve coordination with county agencies when timely action is critical.

Lastly, good faith remains the general governing standard. When a bank acts to protect a vulnerable customer based on reasonable observations and within established procedures, the law supports those efforts. Banks should focus on safeguarding customers, documenting their decision making, and engaging the appropriate authorities when necessary.

When uncertainty arises, consultation with appropriate staff is appropriate, but it should not delay protective action that may prevent significant financial harm.

Conclusion Protecting older and vulnerable customers from financial exploitation requires both vigilance and confidence in the legal tools available to banks. Federal privacy law, Wisconsin’s adult protective services framework, and the newer contact-authorization process under Wis. Stat. § 224.45 all work together to support the important role banks play in identifying and responding to suspected financial abuse. When banks understand how these frameworks align, develop appropriate policies and procedures, and training, responding to elder financial abuse situations becomes more straightforward, prompt, and clear. It can also make all the difference in helping to protect customers. A well-informed and well-prepared banking workforce remains one of the most effective safeguards Wisconsin has to help fight against elder financial abuse.

Additional Resources: Information regarding access to information (including sample MOU): https://www.dhs.wisconsin.gov/aps/sn5finex.pdf Additional documents such as MOU Guidelines for Financial Institutions, Signs of Elder Financial Abuse, among others, can be found in the Wisconsin Department of Health Services Information and Publication Library here: https://www.dhs. wisconsin.gov/publications/index.htm December 2025 | Page 7

Special Focus Interagency Guidance on Privacy Laws and Reporting Financial Abuse of Older Adults: https://occ.gov/news-issuances/ news-releases/2013/nr-ia-2013-148a.pdf

WDFI Division of Banking 2026 Escrow Rate – 0.17% The Wisconsin Department of Financial Institutions (WDFI), Division of Banking, has calculated the interest rate required to be paid on required escrow accounts for residential mortgage loans subject to sec. 138.052(5), Stats., to be 0.17% for 2026. The interest rate be in effect January 1, 2026 through December 31, 2026.

Pursuant to sec. 138.052(5)(am), Stats., except as provided in sec. 138.052(5)(am)(b), Stats., and unless the escrow funds are held by a third-party in a noninterest-bearing account, financial institutions which originate a loan on or after January 1, 1994, and before April 18, 2018, and which requires an escrow account must pay interest on the outstanding principal balance of the escrow at the rate established by WDFI’s Division of Banking. Section 138.052 applies to a consumer-purpose loan secured by a first lien or first lien equivalent in a 1-4 family dwelling that is used as the borrower’s principal residence.

WDFI’s 2026 Escrow Rate: https://dfi.wi.gov/Pages/FinancialInstitutions/BankingSavingsInstitutions/EscrowNotice.aspx

Regulatory Spotlight Agencies Modify Enhanced Supplemental Leverage Ratio Standards.

The Board of Governors of the Federal Reserve System (FRB), Federal Deposit Insurance Corporation (FDIC), and Office of the Comptroller of the Currency (OCC) (collectively, the agencies) issued a final rule to modify the enhanced supplementary leverage ratio standards applicable to U.S. bank holding companies identified as global systemically important bank holding companies (GSIBs), their subsidiary depository institutions that are FRB- or FDIC-regulated, and national banks and Federal savings associations that are subsidiaries of a U.S. top-tier bank holding company with total consolidated assets of more than $700 billion or assets under custody of more than $10 trillion. FRB has also finalized conforming amendments to its total loss-absorbing capacity and long-term debt requirements. In addition, FRB has made conforming amendments to relevant regulatory reporting forms, and FRB and FDIC have made final certain technical corrections to the capital rule and the prompt corrective action framework. Banking organizations subject to the final rule may elect to early adopt the final rule as of 01/01/2026. The final rule is effective 04/01/2026. The final rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-12-01/pdf/2025-21626.pdf. Federal Register, Vol. 90, No. 228, 12/01/2026, 55248-55292.

Agencies Rescind Guidance on Climate-Related Financial Risk Management.

The Board of Governors of the Federal Reserve System (FRB), Federal Deposit Insurance Corporation (FDIC), and Office of the Comptroller of the Currency (OCC) (collectively, the agencies) announced the rescission of the Interagency Principles for Climate-Related Financial Risk Management for Large Financial Institutions. The interagency guidance published in the Federal Register 10/30/2023, is rescinded as of 11/18/2025. The notice may be viewed at: https://www. govinfo.gov/content/pkg/FR-2025-11-18/pdf/2025-20213.pdf. Federal Register, Vol. 90, No. 220, 11/18/2025, 5175651757.

Agencies Propose Revisions to CBLR Framework.

The Board of Governors of the Federal Reserve System (FRB), Federal Deposit Insurance Corporation (FDIC), and Office of the Comptroller of the Currency (OCC) (collectively, the agencies) seek comment regarding a proposed rule that would Page 8 | December 2025

Regulatory Spotlight lower the community bank leverage ratio (CBLR) requirement for certain depository institutions and depository institution holding companies from 9 percent to 8 percent. The proposed rule would also extend the length of time that depository institutions or depository institution holding companies can remain in the CBLR framework while not meeting all of the qualifying criteria for the CBLR framework from two quarters to four quarters, subject to a limit of eight quarters in any five-year period. Comments are due 01/30/2026. The proposed rule may be viewed at: https://www.govinfo.gov/content/ pkg/FR-2025-12-01/pdf/2025-21625.pdf. Federal Register, Vol. 90, No. 228, 12/01/2025, 55048-55063.

Agencies Request Information to Streamline the Call Report.

The Board of Governors of the Federal Reserve System (FRB), Federal Deposit Insurance Corporation (FDIC), and Office of the Comptroller of the Currency (OCC) (collectively, the agencies) request information on sources of regulatory reporting burden for institutions that currently file the Consolidated Reports of Condition and Income (Call Report) (FFIEC 031, FFIEC 041, and FFIEC 051). The request for information offers the opportunity for stakeholders to identify ways the agencies could streamline the Call Report forms and instructions while still meeting the purposes of the collection.

Comments are due 01/30/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-12-01/ pdf/2025-21621.pdf. Federal Register, Vol. 90, No. 228, 12/01/2025, 55240-55243.

CFPB Proposes to Amend Regulation B for Disparate Impact.

The Bureau of Consumer Financial Protection (CFPB) issued a proposed rule to amend provisions related to disparate impact, discouragement of applicants or prospective applicants, and special purpose credit programs under Regulation B, the regulation implementing the Equal Credit Opportunity Act (ECOA). The amendments would facilitate compliance with ECOA by clarifying the obligations imposed by statute. Comments are due 12/15/2025. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-11-13/pdf/2025-19864.pdf. Federal Register, Vol. 90, No. 217, 11/13/2025, 50901-50923.

CFPB Proposes Section 1071 Revisions.

CFPB issued a proposed rule to revise provisions of Regulation B related to section 1071 of the Dodd Frank Act (Section 1071). CFPB is reconsidering coverage of certain credit transactions and financial institutions; the small business definition; inclusion of certain data points and how others are collected; and the compliance date. CFPB believes the proposed changes would streamline the rule, reduce complexity for lenders, and improve data quality, advancing the purposes of section 1071 and complying with recent executive directives. Comments are due 12/15/2025. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-11-13/pdf/2025-19865.pdf. Federal Register, Vol. 90, No. 217, 11/13/2025, 50952-51011.

CFPB Seeks Comment on Information Collections.

CFPB seeks comment regarding an information collection titled, Consumer Response Intake Form. The form is designed to aid consumers in the submission of complaints, inquiries, and feedback and to help CFPB fulfill its statutory requirements. The questions within the form prompt respondents for a description of, and key facts about, the complaint at issue, the desired resolution, contact and account information, information about the company they are submitting a complaint about, and previous action taken to attempt to resolve the complaint. Comments are due 01/27/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-11-28/pdf/2025-21451.pdf Federal Register, Vol. 90, No. 227, 11/28/2024, 54643.

CFPB seeks comment regarding an information collection titled, Consumer Complaint Intake System Company Portal Boarding Form. The portal allows companies to view and respond to complaints submitted to CFPB, supports the efficient routing of consumer complaints to companies, and enables a timely and secure response by companies to CFPB and consumers. Comments are due 12/29/2025. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR2025-11-28/pdf/2025-21453.pdf. Federal Register, Vol. 90, No. 227, 11/28/2025, 54643-54644.

CFPB seeks comment regarding an information collection titled, Disclosure Requirements for Depository Institutions Lacking Federal Deposit Insurance, Regulation I. Regulation I applies to all depository institutions lacking Federal deposit insurance. It requires the disclosure of certain insurance-related information in periodic statements, account records, December 2025 | Page 9

Regulatory Spotlight locations where deposits are normally received, and advertising. The regulation also requires such depository institutions to obtain a written acknowledgment from depositors regarding the institution’s lack of Federal deposit insurance.

Comments are due 02/09/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-12-09/ pdf/2025-22370.pdf. Federal Register, Vol. 90, No. 234, 12/09/2025, 57033-57034.

CFPB seeks comment regarding an information collection titled, Interstate Land Sales Full Disclosure Act, Regulations J, K, and L. The Interstate Land Sales Full Disclosure Act (ILSA) requires land developers to register subdivisions of 100 or more non-exempt lots with CFPB before selling or leasing the lots, and to provide each lot purchaser with a disclosure document designated as a property report. Information is submitted to CFPB to assure compliance with ILSA and the implementing regulations. Comments are due 02/09/2026. The notice may be viewed at: https://www.govinfo.gov/ content/pkg/FR-2025-12-09/pdf/2025-22368.pdf. Federal Register, Vol. 90, No. 234, 12/09/2025, 57034-57035.

CFPB seeks comment regarding an information collection titled, Privacy of Consumer Financial Information, Regulation P. The information collection is used in connection with recordkeeping requirements of Regulation P as described in the notice. Comments are due 02/09/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-1209/pdf/2025-22367.pdf. Federal Register, Vol. 90, No. 234, 12/09/2025, 57035.

CFPB seeks comment regarding an information collection titled, Mortgage Acts and Practices-Advertising, Regulation N. Regulation N prohibits misrepresentations about the terms of mortgage credit products in commercial communications and requires that covered persons keep certain related records for a period of twenty-four months from last dissemination. The information that Regulation N requires covered persons to retain is necessary to ensure efficient and effective law enforcement to address deceptive practices that occur in the mortgage advertising area. Comments are due 02/09/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-12-09/pdf/2025-22366.pdf.

Federal Register, Vol. 90, No. 234, 12/09/2025, 57035-57036.

CFPB seeks comment regarding an information collection titled, Prohibition on Inclusion of Adverse Information in Consumer Reporting in Cases of Human Trafficking, Regulation V. Regulation V sets forth disclosures that need given consumers about information shared with a consumer reporting agency and options which permit consumers to elect not to have information shared as described in the notice. Comments are due 02/09/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-12-09/pdf/2025-22365.pdf. Federal Register, Vol. 90, No. 234, 12/09/2025, 57036.

CFPB seeks comment regarding an information collection titled, Home Mortgage Disclosure Act, Regulation C. The information collection is used to collect and report information as required under Regulation C as further described in the notice. Comments are due 02/09/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-1210/pdf/2025-22442.pdf. Federal Register, Vol. 90, No. 235, 12/10/2025, 57184-57185.

CFPB seeks comment regarding an information collection titled, Registration of Mortgage Loan Originators, Regulation G. Regulation G implements the Secure and Fair Enforcement for Mortgage Licensing Act (S.A.F.E. Act), which contains the registration requirements with respect to any covered financial institutions and their employees who act as residential mortgage loan originators (MLOs), including to adopt and to follow written policies and procedures ensuring their employees comply with these requirements and disclose the unique identifiers of their MLOs. Comments are due 02/09/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-12-10/pdf/2025-22441.pdf.

Federal Register, Vol. 90, No. 235, 12/10/2025, 57185.

CFPB seeks comment regarding an information collection titled, Truth in Savings, Regulation DD. The recordkeeping requirements of Regulation DD ensure that records that might contain evidence of violations remain available to Federal enforcement agencies, as well as to private litigants. Comments are due 02/09/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-12-10/pdf/2025-22440.pdf. Federal Register, Vol. 90, No. 235, 12/10/2025, 57185-57186.

FRB Issues Final Rules to Amend Regulations A and D. The Board of Governors of the Federal Reserve System (FRB) issued a final rule to adopt amendments to its Regulation A to reflect FRB’s approval of a decrease in the rate for primary credit at each Federal Reserve Bank. The secondary credit rate at each Reserve Bank automatically decreased by formula as a result of FRB’s primary credit rate action. On Page 10 | December 2025

Regulatory Spotlight 10/29/2025, FRB voted to approve a 0.25 percentage point decrease in the primary credit rate, thereby decreasing the primary credit rate from 4.25 percent to 4.00 percent. In addition, FRB had previously approved the renewal of the secondary credit rate formula, the primary credit rate plus 50 basis points. Under the formula, the secondary credit rate decreased by 0.25 percentage points as a result of FRB’s primary credit rate action, thereby decreasing the secondary credit rate from 4.75 percent to 4.50 percent. The amendments to Regulation A reflect these rate changes. The final rule is effective 11/14/2025. The final rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-11-14/ pdf/2025-19888.pdf. Federal Register, Vol. 90, No. 218, 11/14/2025, 51017-51018.

FRB issued a final rule to adopt amendments to its Regulation D to revise the rate of interest paid on balances (IORB) maintained at Federal Reserve Banks by or on behalf of eligible institutions. The final amendments specify that IORB is 3.90 percent, a 0.25 percentage point decrease from its prior level. The amendment is intended to enhance the role of IORB in maintaining the federal funds rate in the target range established by the Federal Open Market Committee. The final rule is effective 11/14/2025. The final rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-11-14/ pdf/2025-19889.pdf. Federal Register, Vol. 90, No. 218, 11/14/2025, 51018-51019.

FRB issued a final rule to amend Regulation D, Reserve Requirements of Depository Institutions, to reflect the annual indexing of the reserve requirement exemption amount and the low reserve tranche for 2026. The annual indexation of these amounts is required notwithstanding FRB’s action in March 2020 of setting all reserve requirement ratios to zero.

FRB has amended Regulation D to set the reserve requirement exemption amount at $39.2 million (increased from $37.8 million in 2025) and the amount of the low reserve tranche at $674.1 million (increased from $645.8 million in 2025). The adjustments to both of the amounts are derived using statutory formulas specified in the Federal Reserve Act. The annual indexation of the reserve requirement exemption amount and low reserve tranche is required by statute but will not affect depository institutions’ reserve requirements, which will remain zero. The final rule is effective 12/24/2025. The new exemption amount and low reserve tranche will apply beginning 01/01/2026. The final rule may be viewed at: https:// www.govinfo.gov/content/pkg/FR-2025-11-24/pdf/2025-20744.pdf. Federal Register, Vol. 90, No. 224, 11/24/2025, 52849-52851.

FRB Adjusts Federal Reserve Bank Capital Stock Dividend Threshold.

FRB issued a final rule that applies an inflation adjustment to the threshold for total consolidated assets in Regulation I. Federal Reserve Bank (Reserve Bank) stockholders that have total consolidated assets above the threshold receive a different dividend rate on their Reserve Bank stock than stockholders with total consolidated assets at or below the threshold. The Federal Reserve Act requires that FRB annually adjust the total consolidated asset threshold to reflect the change in the Gross Domestic Product Price Index, published by the Bureau of Economic Analysis. Based on the change in the Gross Domestic Product Price Index as of 09/25/2025, the total consolidated asset threshold will be $13,182,000,000 through 12/31/2026. The final rule is effective 12/22/2025. The adjusted threshold for total consolidated assets will apply beginning on 01/01/2026. The final rule may be viewed at: https://www.govinfo.gov/ content/pkg/FR-2025-11-20/pdf/2025-20472.pdf. Federal Register, Vol. 90, No. 222, 11/20/2025, 52231-52232.

FRB Revises LFI Rating System and Framework for Supervision of Insurance Organizations.

FRB issued a final notice to revise its Large Financial Institution (LFI) rating system (LFI Framework) and the rating system for depository institution holding companies significantly engaged in insurance activities (Insurance Supervisory Framework, together with the LFI Framework, Frameworks) to more appropriately identify as “well managed” firms that have sufficient financial and operational strength and resilience to maintain safe and sound operations through a range of conditions, including stressful ones. The final notice also replaces the presumption in the Frameworks that firms with one or more Deficient-1 component ratings will be subject to a formal or informal enforcement action with a statement that such firms may be subject to a formal or informal enforcement action, depending on particular facts and circumstances.

The final notice also removes a reference to reputational risk in the Insurance Supervisory Framework. The final notice is effective 01/16/2026. The final notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-11-17/ pdf/2025-19945.pdf. Federal Register, Vol. 90, No. 219, 11/17/2025, 51329-51354.

FRB Announces Final Approval of Information Collections.

FRB announced final approval of an information collection titled, Payments Research Survey. FRB uses the collection to December 2025 | Page 11

Regulatory Spotlight obtain information, as needed, on specific and time-sensitive issues, related to payments research, which may provide insights that augment the Federal Reserve System’s effectiveness within the payments system. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-11-17/pdf/2025-19931.pdf. Federal Register, Vol. 90, No. 219, 11/17/2025, 51354.

FRB announced final approval of an information collection titled, Recordkeeping and Disclosure Requirements Associated with Regulation H (Loans Secured by Real Estate Located in Flood Hazard Areas). The information collection is used in connection with recordkeeping and disclosure provisions of Regulation H regarding flood insurance. The information collection requirements under the flood hazard provisions of Regulation H are triggered by specific events in the lending process. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-11-17/pdf/2025-19934.pdf.

Federal Register, Vol. 90, No. 219, 11/17/2025, 51354-31355.

FRB announced final approval of information collections titled, Consumer Complaint Form; and Interagency Appraisal Complaint Form. The consumer complaint form allows consumers to submit a complaint against a financial institution.

The appraisal complaint form collects information about complaints regarding a regulated institution’s non-compliance with the appraisal independence standards and the Uniform Standards of Professional Appraisal Practice, including complaints from appraisers, individuals, and other entities. The information is used to respond to consumer complaints and inquiries regarding practices by banks and other financial institutions supervised by FRB. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-11-17/pdf/2025-19936.pdf. Federal Register, Vol. 90, No. 219, 11/17/2025, 51355.

FRB announced final approval of an information collection titled, Recordkeeping and Disclosure Requirements Associated with Regulation CC. The information collection was revised to take into account certain existing provisions within Regulation CC that had not yet been included in previous information collections. The revisions to the information collection are effective 12/17/2025. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-11-17/ pdf/2025-19932.pdf. Federal Register, Vol. 90, No. 219, 11/17/2025, 31355-31356.

FRB announced final approval of an information collection titled, Federal Reserve Membership and Bank Stock Applications. The Federal Reserve Membership Application collection is used by state-chartered banks converting to a state member bank, national banks converting to a state charter, and mutual savings banks applying for membership in the Federal Reserve System. The Federal Reserve Bank Stock Application collection is used by national banks seeking to purchase Federal Reserve Bank stock, nonmember state banks converting into a national bank, federal savings associations that have elected to operate as a covered savings association (CSA), CSAs terminating an election to operate as a CSA, and member banks seeking to increase, decrease, or cancel their FRB stock holdings. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-12-08/pdf/2025-22259.pdf. Federal Register, Vol. 90, No. 233, 12/08/2025, 56753-56754.

FRB announced final approval of an information collection titled, Reporting and Disclosure Requirements Associated with Regulation G. Regulation G implements section 711 of the Gramm-Leach-Bliley Act, which requires insured depository institutions (IDIs), affiliates of IDIs, and nongovernmental entities or persons (NGEPs) to disclose written agreements entered into in connection with fulfillment of the Community Reinvestment Act. The notice may be viewed at: https:// www.govinfo.gov/content/pkg/FR-2025-12-08/pdf/2025-22262.pdf. Federal Register, Vol. 90, No. 233, 12/08/2025, 56754.

FRB announced final approval of an information collection titled, United States Currency Program Surveys. The U.S. Currency Program Surveys are used to obtain information specifically tailored to FRB’s operational and fiscal agency responsibilities. Several revisions were made to the information collection as described in the notice. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-12-08/pdf/2025-22260.pdf. Federal Register, Vol. 90, No. 233, 12/08/2025, 56755-56756.

FRB announced final approval of an information collection titled, Financial Statements for Holding Companies. FRB requires bank holding companies, most savings and loan holding companies, securities holding companies, and U.S. intermediate holding companies to provide standardized financial statements through one or more reporting forms within the information collection as further described in the notice. The notice may be viewed at: https://www.govinfo.gov/ content/pkg/FR-2025-12-08/pdf/2025-22264.pdf. Federal Register, Vol. 90, No. 233, 12/08/2025, 56756-56759.

Page 12 | December 2025

Regulatory Spotlight FRB announced final approval of an information collection titled, Recordkeeping and Disclosure Requirements Associated with the CFPB’s Regulation E. FRB-supervised institutions must provide meaningful disclosures about the basic terms, costs, and rights relating to electronic fund transfer services involving a customer’s account and must maintain certain records. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-12-08/pdf/2025-22258.pdf.

Federal Register, Vol. 90, No. 233, 12/08/2025, 56759-56760.

FRB announced final approval of an information collection titled, Reporting, Recordkeeping, and Disclosure Requirements Associated with Regulation BB. The Community Reinvestment Act (CRA) directs FRB, Federal Deposit Insurance Corporation (FDIC), and Office of the Comptroller of the Currency (OCC) to evaluate financial institutions’ (banks and savings associations) records of helping to meet the credit needs of their entire communities, including low- and moderate-income areas, consistent with the safe and sound operation of the institutions. The reporting, recordkeeping, and disclosure requirements of the information collection in FRB’s regulation apply to state member banks. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-12-08/pdf/2025-22261.pdf. Federal Register, Vol. 90, No. 233, 12/08/2025, 56760.

FRB announced final approval of an information collection titled, Recordkeeping and Disclosure Requirements Associated with CFPB’s and FRB’s Regulations V. The Consumer Financial Protection Bureau’s (CFPB) Regulation V and FRB’s Regulation V implement in part the Fair Credit Reporting Act (FCRA). FCRA requires consumer reporting agencies to adopt reasonable procedures that are fair and equitable to the consumer with regard to the confidentiality, accuracy, relevancy, and proper utilization of consumer information. FRB is responsible for the information collection requirements contained in CFPB’s Regulation V for institutions with $10 billion or less in assets and for consumers of these institutions, as well as for the identity theft red flags provisions in FRB’s Regulation V for institutions of any size. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-12-08/pdf/2025-22263.pdf. Federal Register, Vol. 90, No. 233, 12/08/2025, 56760-56761.

FRB Expands Fedwirer® Funds Service and NSS Hours.

FRB announced that the Federal Reserve Banks (Reserve Banks) will expand the operating hours for the Fedwire Funds Service to 22 hours per day, 6 days per week, operating Sunday through Friday, including weekday holidays (22x6). FRB also announced a corresponding expansion of the National Settlement Service’s (NSS) operating hours to 21.5 hours per day, 6 days per week, operating Sunday through Friday, including weekday holidays, with NSS closing 30 minutes earlier than the Fedwire Funds Service. FRB expects the Reserve Banks to implement the expansion in 2028 or 2029 to ensure technological, operational, and industry readiness. FRB will monitor industry demand and will stand ready to offer an additional expansion up to 22x7x365 no sooner than two years after the Reserve Banks implement 22x6 operations. If FRB does propose to expand operating hours beyond 22x6, it will seek comment in a separate proposal. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-11-17/pdf/2025-19942.pdf. Federal Register, Vol. 90, No. 219, 11/17/2025, 51356-51368.

FRB Announces 2026 Private-Sector Adjustment Factor and Fee Schedule.

FRB announced approval of the private-sector adjustment factor (PSAF) for 2026 of $34.1 million and the 2026 fee schedules for Federal Reserve priced services and electronic access. See the notice for the new rates. The new fee schedules are effective 01/01/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-12-09/ pdf/2025-22268.pdf. Federal Register, Vol. 90, No. 234, 12/09/2025, 57052-57062.

FRB Issues Proposed Rule on Supervisory Stress Test Models and Testing Framework.

FRB seeks comment on the models used to conduct its supervisory stress test, changes to the models to be implemented in the 2026 stress test, and proposed changes to enhance the transparency and public accountability of FRB’s stress testing framework. The proposal would amend the Policy Statement on the Scenario Design Framework for Stress Testing, including to implement guides for additional scenario variables, and the Stress Testing Policy Statement. The proposal would also codify an enhanced disclosure process under which FRB would annually publish comprehensive documentation on the stress test models, invite comment on any material changes that FRB seeks to make to the models, and annually publish the stress test scenarios for comment. Lastly, the proposal would make changes to the FR Y-14A/ Q/M to remove items that are no longer needed to conduct the supervisory stress test and to collect additional data to December 2025 | Page 13

Regulatory Spotlight support the stress test models and improve risk capture. FRB also issued a notice to extend the original comment period of 01/22/2026 to 02/21/2026. Comments are due 02/21/2026. The proposed rule may be viewed at: https://www. govinfo.gov/content/pkg/FR-2025-11-18/pdf/2025-20211.pdf. Federal Register, Vol. 90, No. 220, 11/18/2025, 5185651953. The notice to extend the comment period may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-1125/pdf/2025-21087.pdf. Federal Register, Vol. 90, No. 225, 11/25/2025, 53238.

FRB Seeks Comment on Branch Closure Notice.

FRB seeks comment regarding an information collection titled, Notice of Branch Closure. The reporting, recordkeeping, and disclosure requirements regarding the closing of any branch of an insured depository institution (IDI) are contained in section 42 of the Federal Deposit Insurance Act, as supplemented by an interagency policy statement on branch closings. FRB uses the information collection to fulfill its statutory obligation to supervise state member banks. Each IDI must adopt a policy regarding the closing of its branches. When a branch is scheduled for closing, the IDI must notify both its appropriate regulator and its customers of the proposed closure. Comments are due 01/16/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-11-17/pdf/2025-19933.pdf. Federal Register, Vol. 90, No. 219, 11/17/2025, 51328-51329.

FRB Requests Information on Future of Check Services.

FRB requests information related to the future of its check services. FRB will use responses to the request for information (RFI) to assess possible strategies for the future of FRB’s check services, including potentially substantial changes that may have longer run effects on the payments system. In addition, FRB will use responses to the RFI to analyze other actions that FRB could consider with respect to checks, in partnership with the industry, to support the overall safety and efficiency of the payments system. Comments are due 03/09/2026. The notice may be viewed at: https://www.govinfo. gov/content/pkg/FR-2025-12-09/pdf/2025-22272.pdf. Federal Register, Vol. 90, No. 234, 12/09/2025, 57062-57067.

FDIC Delays Compliance Date for Portions of Official Signage Rule.

The Federal Deposit Insurance Corporation (FDIC) issued a final rule to postpone the mandatory compliance date.

On 12/20/2023, FDIC adopted a final rule that, among other things, amended its official sign and advertisement of membership requirements for insured depository institutions (IDIs). The current compliance date for requirements related to displaying the official digital sign on IDIs’ digital deposit-taking channels and automated teller machines (ATMs) and like devices is 03/01/2026. FDIC has delayed the 03/01/2026, compliance date to 01/01/2027. The compliance date for the requirements in 12 CFR 328.4 and 328.5 is delayed to 01/01/2027. The final rule may be viewed at: https://www. govinfo.gov/content/pkg/FR-2025-11-28/pdf/2025-21461.pdf. Federal Register, Vol. 90, No. 227, 11/28/2025, 5454454545.

FDIC Adjusts and Indexes Certain Regulatory Thresholds.

FDIC issued a final rule to amend certain thresholds in its regulations to reflect inflation. Specifically, the final rule generally updates such thresholds to reflect inflation from the date of initial implementation or the most recent adjustment and provides for future adjustments pursuant to an indexing methodology. The changes set forth in the final rule preserve the level of certain thresholds set forth in FDIC’s regulations in real terms, thereby avoiding the undesirable and unintended outcome where the scope of applicability for a regulatory requirement changes due solely to inflation rather than actual changes in an institution’s size, risk profile, or level of complexity. The final rule is effective 01/01/2026.

An insured depository institution (IDI) need not comply with the applicable 12 CFR part 363 requirements in effect as of 12/31/2025, if the IDI will not be subject to 12 CFR part 363 requirements under the updated thresholds in effect as of 01/01/2026, as specified in the final rule. The final rule may be viewed at: https://www.govinfo.gov/content/pkg/FR2025-12-04/pdf/2025-21914.pdf. Federal Register, Vol. 90, No. 231, 12/04/2025, 55789-55812.

FDIC Announces 2026 Designated Reserve Ratio.

FDIC announced the Designated Reserve Ratio (DRR) for 2026. Pursuant to the Federal Deposit Insurance Act, FDIC designates that the DRR for the Deposit Insurance Fund shall remain at 2 percent for 2026. The notice may be viewed at: https://www. govinfo.gov/content/pkg/FR-2025-11-28/pdf/2025-21460.pdf. Federal Register, Vol. 90, No. 227, 11/28/2025, 54688-54689.

Page 14 | December 2025

Regulatory Spotlight FDIC Seeks Comment on Information Collections.

FDIC seeks comments on four information collections titled: Home Mortgage Disclosure Act; Management Official Interlocks; Funding and Liquidity Risk Management; and Appraisals for Higher-Priced Mortgage Loans. The collections are used as described in the notice. Comments are due 02/09/2026. The notice may be viewed at: https://www.govinfo. gov/content/pkg/FR-2025-12-09/pdf/2025-22359.pdf. Federal Register, Vol. 90, No. 234, 12/09/2025, 57049-57051.

OCC Proposes Amendments to Community Bank Licensing.

The Office of the Comptroller of the Currency (OCC) issued a proposed rule to amend its rules to simplify licensing requirements for corporate activities and transactions involving national banks and Federal savings associations that have less than $30 billion in total assets and satisfy certain conditions. The proposed rule is intended to reduce burden.

Comments are due 01/20/2026. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-202511-18/pdf/2025-20204.pdf. Federal Register, Vol. 90, No. 220, 11/18/2025, 51577-51583.

OCC Proposes to Rescind Fair Housing Home Loan Data System.

OCC issued a proposed rule to rescind its Fair Housing Home Loan Data System regulation codified at 12 CFR part 27.

OCC has determined that the regulation is obsolete and largely duplicative of and inconsistent with other legal authorities that require national banks to collect and retain certain information on applications for home loans. Moreover, part 27 imposes asymmetrical data collection requirements on national banks compared to their other depository institution counterparts, and the data collected has limited utility. Comments are due 12/18/2025. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-11-18/pdf/2025-20202.pdf. Federal Register, Vol. 90, No. 220, 11/18/2025, 51583-51587.

OCC Proposes to Rescind Recovery Planning Guidelines.

OCC issued a proposed rule to amend 12 CFR part 30 by rescinding appendix E, OCC Guidelines Establishing Standards for Recovery Planning by Certain Large Insured National Banks, Insured Federal Savings, and Insured Federal Branches.

The guidelines cause covered banks to direct significant resources towards developing responsive documentation.

OCC believes existing safety and soundness standards require all banks to have effective risk management processes, including in times of stress, that is commensurate with the size, complexity, and risk of their activities. Comments are due 12/18/2025. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-11-18/pdf/202520199.pdf. Federal Register, Vol. 90, No. 220, 11/18/2025, 51587-51590.

OCC Seeks Information on Core Service Providers and Other Essential Third-Party Service Providers.

OCC issued a request for information (ROI) on community bank engagement with their core service providers and other essential third-party service providers. OCC seeks to better understand how challenges community banks face with such service providers affect banks’ abilities to remain competitive in a rapidly evolving marketplace, as well as what actions OCC can take to address any of the challenges. Comments are due 01/27/2026. The ROI may be viewed at: https://www. govinfo.gov/content/pkg/FR-2025-11-28/pdf/2025-21333.pdf. Federal Register, Vol. 90, No. 227, 11/28/2025, 5488254886.

OCC Seeks Comment on Information Collections.

OCC seeks comments regarding an information collection titled, Stress Testing Rules for National Banks and Federal Savings Associations. The Annual Stress Test rule implemented Section 165(i) of the Dodd Frank Act which requires certain companies to conduct stress tests. The information collection is used in connection with stress test requirements.

Comments are due 01/23/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-11-24/ pdf/2025-20752.pdf. Federal Register, Vol. 90, No. 224, 11/24/2025, 53059-53060.

OCC seeks comments regarding an information collection titled, Extensions of Credit to Insiders and Transactions with Affiliates. National banks and Federal savings associations must comply with rules of the Board of Governors of December 2025 | Page 15

Regulatory Spotlight the Federal Reserve System regarding extensions of credit to insiders (Regulation O) and transactions with affiliates (Regulation W), which implement section 22(h) and sections 23A and 23B, respectively, of the Federal Reserve Act (FRA). Twelve CFR part 31.2 requires national banks, Federal savings associations, and their insiders to comply with Regulation O, and 12 CFR 31.3 requires national banks and Federal savings associations to comply with Regulation W. Section 31.3(c) implements the statutory standards for authorizing an exemption from section 23A of the FRA or section 11 of the Homeowners’ Loan Act (HOLA) in accordance with the Dodd Frank Act. The information collection is used in connection with requesting an exemption. Comments are due 01/26/2026. The notice may be viewed at: https://www. govinfo.gov/content/pkg/FR-2025-11-25/pdf/2025-20960.pdf. Federal Register, Vol. 90, No. 225, 11/25/2025, 5341953420.

OCC seeks comments regarding an information collection titled, Company-Run Annual Stress Test Reporting Template and Documentation for Covered Institutions with Total Consolidated Assets of $250 Billion or More under the Dodd Frank Act. The use of the information collection and proposed changes are discussed in the notice. Comments are due 01/27/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-11-28/pdf/2025-21317.pdf.

Federal Register, Vol. 90, No. 227, 11/28/2025, 54886-54887.

OCC seeks comments regarding an information collection titled, Guidance on Sound Incentive Compensation Policies.

Under the guidance, each large national bank and Federal savings association should have policies and procedures, documentation, audit, and board of director review of incentive compensation arrangements based upon the size and complexity of a banking organization. Comments are due 02/02/2026. The notice may be viewed at: https://www.govinfo. gov/content/pkg/FR-2025-12-04/pdf/2025-21896.pdf. Federal Register, Vol. 90, No. 231, 12/04/2025, 55974-55975.

OCC seeks comments regarding an information collection titled, Financial Management Policies-Interest Rate Risk. The information collection covers the recordkeeping burden for Federal savings associations to maintain data in accordance with OCC’s regulation on interest rate risk procedures. Comments are due 02/09/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-12-09/pdf/2025-22328.pdf. Federal Register, Vol. 90, No. 234, 12/09/2025, 57130-57131.

HUD Announces FY 2026 Section 108 Loan Guarantee Borrower Fee. The Department of Housing and Urban Development (HUD) announced the fee it will collect from borrowers of loans guaranteed under its Section 108 Loan Guarantee Program to offset the credit subsidy costs of the guaranteed loans.

The fee to offset credit subsidy costs is changing from 0.82 percent in Fiscal Year (FY) 2025 to 0.58 percent in FY 2026.

The change is applicable 10/01/2025. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-1119/pdf/2025-20345.pdf. Federal Register, Vol. 90, No. 221, 11/19/2025, 51992-51994.

HUD Seeks Comment on Servicing HECM Information Collection.

HUD seeks comment regarding an information collection titled, Performing Loans Servicing for the Home Equity Conversion Mortgage (HECM). The information request is a comprehensive collection of requirements for mortgagees that service HECMs and HECM borrowers, who are involved with servicing-related activities that includes collection and payment of mortgage insurance premiums, escrow account administration, providing loan information and customer service. Comments are due 01/05/2025. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-202512-04/pdf/2025-21926.pdf. Federal Register, Vol. 90, No. 231, 12/04/2025, 55877-55878.

FEMA Adjusts Thresholds for Floodplain Management and Wetlands Protection Review Process.

The Federal Emergency Management Agency (FEMA) announced the dollar value thresholds that provide exemption from or abbreviation of the floodplain management and wetlands protection process for certain Public Assistance projects associated with disasters with an incident start date on or after 10/01/2025, will increase as outlined in the notice. The adjustments apply to major disasters with an incident start date on 10/01/2025. The notice may be viewed at: https:// www.govinfo.gov/content/pkg/FR-2025-11-18/pdf/2025-20059.pdf. Federal Register, Vol. 90, No. 220, 11/18/2025, 51771.

Page 16 | December 2025

Regulatory Spotlight FEMA Issues Final Flood Hazard Determinations.

FEMA announced final hazard determinations, which may include additions or modifications of Base Flood Elevations (BFEs), base flood depths, Special Flood Hazard Area (SFHA) boundaries or zone designations, or regulatory floodways on the Flood Insurance Rate Maps (FIRMs) and where applicable, in the supporting Flood Insurance Study (FIS) reports have been made final for communities in the state Wisconsin. The FIRM and FIS report are the basis of the floodplain management measures that a community is required either to adopt or to show evidence of having in effect in order to qualify or remain qualified for participation in FEMA’s National Flood Insurance Program (NFIP). The date of 02/20/2026, has been established for the FIRM and, where applicable, the supporting FIS report showing the new or modified flood hazard information for each community. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-202512-08/pdf/2025-22246.pdf. Federal Register, Vol. 90, No. 233, 12/08/2025, 56786-56787.

FEMA Issues Final Changes in Flood Hazard Determinations.

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 the states of Indiana, Michigan, 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-2025-11-20/pdf/2025-20377.pdf. Federal Register, Vol. 90, No. 222, 11/20/2025, 52414-52417.

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 the states of Indiana and Minnesota, 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-2025-11-20/pdf/2025-20376.pdf. Federal Register¸ Vol. 90, No. 222, 11/20/2025, 52423-52425.

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 the states of Illinois 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-2025-12-08/pdf/2025-22239.pdf. Federal Register, Vol. 90, No. 233, 12/08/2025, 56780-56783.

FEMA Announces Changes in Flood Hazard Determinations.

FEMA issued a notice which lists communities in the states of Indiana and Minnesota, where the addition or modification of Base Flood Elevations (BFEs), base flood depths, Special Flood Hazard Area (SFHA) boundaries or zone designations, or the regulatory floodway (hereinafter referred to as flood hazard determinations), as shown on the Flood Insurance Rate Maps (FIRMs), and where applicable, in the supporting Flood Insurance Study (FIS) reports is appropriate because of new scientific or technical data. The FIRM, and where applicable, portions of the FIS report, have been revised to reflect the flood hazard determinations through issuance of a Letter of Map Revision (LOMR), in accordance with federal regulations.

The flood hazard determinations will be finalized on the dates listed in the table in the notice and revise the FIRM panels and FIS report in effect prior to the determination for the listed communities. From the date of the second publication of notification of the changes in a newspaper of local circulation, any person has 90 days in which to request through the community that the Deputy Associate Administrator for Insurance and Mitigation reconsider the changes. The flood hazard determination information may be changed during the 90-day period. The notice may be viewed at: https://www. govinfo.gov/content/pkg/FR-2025-11-20/pdf/2025-20374.pdf. Federal Register, Vol. 90, No. 222, 11/20/2025, 5241952422.

December 2025 | Page 17

Regulatory Spotlight FEMA issued a notice which lists communities in the states of Indiana, Michigan, and Minnesota, where the addition or modification of Base Flood Elevations (BFEs), base flood depths, Special Flood Hazard Area (SFHA) boundaries or zone designations, or the regulatory floodway (hereinafter referred to as flood hazard determinations), as shown on the Flood Insurance Rate Maps (FIRMs), and where applicable, in the supporting Flood Insurance Study (FIS) reports is appropriate because of new scientific or technical data. The FIRM, and where applicable, portions of the FIS report, have been revised to reflect the flood hazard determinations through issuance of a Letter of Map Revision (LOMR), in accordance with federal regulations. The flood hazard determinations will be finalized on the dates listed in the table in the notice and revise the FIRM panels and FIS report in effect prior to the determination for the listed communities. From the date of the second publication of notification of the changes in a newspaper of local circulation, any person has 90 days in which to request through the community that the Deputy Associate Administrator for Insurance and Mitigation reconsider the changes. The flood hazard determination information may be changed during the 90-day period. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-12-08/pdf/2025-22240.pdf. Federal Register, Vol. 90, No. 233, 12/08/2025, 56788-56791.

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 the state of Michigan, 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 03/09/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-12-08/ pdf/2025-22242.pdf. Federal Register, Vol. 90, No. 233, 56784-56785.

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 the state of Indiana, 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 03/09/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-12-08/ pdf/2025-22241.pdf. Federal Register, Vol. 90, No. 233, 12/08/2025, 56785-56786.

FinCEN Proposes Special Measure on Ten Mexican Gambling Establishments.

The Financial Crimes Enforcement Network (FinCEN) issued a proposed rule, pursuant to the USA PATRIOT Act, that finds transactions involving ten identified Mexico-based gambling establishments to be a class of transactions of primary money laundering concern, and proposes imposing a special measure to: (1) prohibit U.S. financial institutions from opening or maintaining a correspondent account for any foreign banking institution if such account is used to process transactions involving any of the gambling establishments, and (2) require U.S. financial institutions to apply special due diligence to their correspondent accounts that is reasonably designed to guard against the use of such accounts to process transactions involving any of the gambling establishments. Comments are due 12/17/2025. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-11-17/pdf/2025-19927.pdf. Federal Register, Vol. 90, No. 219, 11/17/2025, 51234-51247.

Treasury Seeks Comment on Excise Taxes Refund Claim Form.

The Department of the Treasury (Treasury) seeks comment regarding an information collection titled, Claim for Refund of Excise Taxes. Internal Revenue Code sections 6402, 6404, 6511 and regulation sections 301.6402-2, 301.6404-1, and 301.6404-3 allow for refunds of taxes (except income taxes) or refund, abatement, or credit of interest, penalties, and additions to tax in the event of errors or certain actions by IRS. Comments are due 01/02/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-12-02/pdf/2025-21735.pdf. Federal Register, Vol. 90, No. 229, 12/02/2025, 55339.

Page 18 | December 2025

Regulatory Spotlight IRS Issues Final Rule on Repurchase of Corporate Stock Excise Tax. The Internal Revenue Service (IRS) issued a final rule to provide guidance regarding the application of excise tax on repurchases of corporate stock made after 12/31/2022. The final rule affects certain publicly traded corporations that repurchase their stock or whose stock is acquired by certain specified affiliates as described in the final rule. The final rule is effective 11/24/2025. See the final rule for applicability dates. The final rule may be viewed at: https://www.govinfo. gov/content/pkg/FR-2025-11-24/pdf/2025-20721.pdf. Federal Register, Vol. 90, No. 224, 11/24/2025, 53144-53190.

IRS Issues Final Rule on Estate Tax Closing Letter User Fee. IRS issued a final rule relating to the imposition of a user fee on authorized persons requesting the issuance of IRS Letter 627, also referred to as an estate tax closing letter. The final rule adopts without change the text of the interim final rule and proposed rule that reduced the amount of the user fee imposed on a request for the issuance of an estate tax closing letter from $67 to $56. The final rule is effective 12/31/2025. The final rule may be viewed at: https://www.govinfo.gov/ content/pkg/FR-2025-12-01/pdf/2025-21649.pdf. Federal Register, Vol. 90, No. 228, 12/01/2025, 55041-55042.

IRS Seeks Comment on Golden Parachute and Vehicle Loan Interest Statement Information Collections.

IRS seeks comment regarding an information collection titled, Golden Parachute Payments. IRS regulations deny a deduction for excess parachute payments. A parachute payment is a payment in compensation to a disqualified individual that is contingent on a change in ownership or control of a corporation. Certain payments, including payments from a small corporation, are exempt from the definition of parachute payment if certain requirements are met (such as shareholder approval and disclosure requirements). Comments are due 01/26/2026. The notice may be viewed at: https:// www.govinfo.gov/content/pkg/FR-2025-11-26/pdf/2025-21092.pdf. Federal Register, Vol. 90, No. 226, 11/26/2025, 54460.

IRS seeks comment regarding an information collection titled, Vehicle Loan Interest Statement. IRS Section 6050AA requires information reporting with respect to interest received on a specified passenger vehicle loan. Recipients of the interest are required to file an information return to IRS and furnish a statement to individuals who pay or accrue the interest during a calendar year. The information collection was developed for the information collection requirement included in IRS Notice 20257. Comments are due 01/26/2026. The notice may be viewed at: https://www.govinfo.gov/ content/pkg/FR-2025-11-26/pdf/2025-21091.pdf. Federal Register, Vol. 90, No. 226, 11/26/2026, 54460-54461.

FHFA Seeks Comment on Community Support and Affordable Housing Information Collections.

The Federal Housing Finance Agency (FHFA) seeks comment regarding an information collection titled, Community Support Requirements. FHFA uses the information collected to assess the responding member’s compliance with the statutory and regulatory community support standards. Comments are due 01/20/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-11-18/pdf/2025-20124.pdf. Federal Register, Vol. 90, No. 220, 11/18/2025, 51757-51758.

FHFA seeks comment regarding an information collection titled, Affordable Housing Program. FHFA uses the information collected to verify that the Federal Home Loan Banks’ funding decisions, and the uses of the funds awarded, were consistent with statutory and regulatory requirements. Comments are due 01/20/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-11-18/pdf/2025-20123.pdf. Federal Register, Vol. 90, No. 220, 11/18/2025, 51758-51761.

SBA Amends SBIC Accrual Regulations.

The Small Business Administration (SBA) issued a direct rule to provide for a clarification in the annual charges assessed for leverage between small business investment company (SBIC) licenses and accrual SBIC licenses. SBA has modified paragraph (d) of 13 CFR 107.1130 to clarify that SBA may calculate annual charges based on the type of debentures issued. The annual charge rates by type of debenture are designed to be fiscally neutral in the aggregate, offsetting reductions and increases across licensee categories without increasing total program cost and keep the SBIC program December 2025 | Page 19

Regulatory Spotlight budget neutral in line with the overall rate and components of the subsidy rate as calculated and reported annually in the Federal Credit Supplement. The direct final rule is effective 01/20/2026, unless significant adverse comment is received no later than 01/05/2026. If significant adverse comment is received, SBA will publish a timely withdrawal of the rule in the Federal Register. The direct final rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-12-05/ pdf/2025-22055.pdf. Federal Register, Vol. 90, No. 232, 12/05/2025, 55997-55999.

FSA Issues Final Rule on Agricultural Disaster Indemnity Programs.

The Farm Service Agency (FSA) issued a final rule to provide assistance for eligible quality losses under Stage 1 of the Supplemental Disaster Relief Program (SDRP) and to implement Stage 2 of SDRP, the On-Farm Stored Commodity Loss Program, and the Milk Loss Program, all of which provide assistance using funding authorized by the American Relief Acts. SDRP provides payments to eligible producers for losses of crops, trees, bushes, and vines due to qualifying disaster events as further described in the final rule. The final rule is effective 11/18/2025. The final rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-11-18/pdf/2025-20132.pdf. Federal Register, Vol. 90, No. 220, 11/18/2025, 51956-51988.

FSA Seeks Comment on ERP Forms.

FSA seeks comment regarding an information collection titled, Emergency Relief Program (ERP) Phase 1 and Phase 2.

The information collection is used to document that ERP recipients meet all statutory requirements. Comments are due 02/03/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-12-05/pdf/2025-21992.pdf.

Federal Register, Vol. 90, No. 232, 12/05/2025, 56125-56126.

FCA Issues Propose Rule on Loan Performance Categories and Financial Reporting.

The Farm Credit Administration (FCA) issued a proposed rule to amend its regulatory high risk loan performance categories by removing “formally restructured loans (TDR),” also known as troubled debt restructurings. 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. FCA proposes removing TDRs from its regulatory loan performance categories to reflect changes in GAAP. Further, FCA seeks comments on its determination that no regulatory changes are needed for the enhanced disclosures related to loan refinancings and restructurings or the amended vintage year disclosure requirements, as the disclosures are already required under applicable GAAP. Additionally, comments are requested on retaining the “90 days past due still accruing interest” loan performance category. Comments are due 02/03/2026. The proposed rule may be viewed at: https://www.govinfo.gov/ content/pkg/FR-2025-12-05/pdf/2025-22015.pdf. Federal Register, Vol. 90, No. 232, 12/05/2025, 56066-56070.

FCIC Clarifies Crop Insurance Policies.

The Federal Crop Insurance Corporation (FCIC) issued a final rule to amend its regulations to implement changes required by the One Big Beautiful Bill Act and to update, streamline, and clarify several crop insurance policies. The changes include clarifying the harvest price methodology, deregulating regionalized program dates and moving information, removing regulatory barriers to direct marketing, incorporating quality adjustment and claims processes, updating FCIC contact information used to request interpretations of policy, and making plain language clarifications and corrections to Subpart X. In addition, the changes include removing buy-up coverage for prevented planting in the crop insurance program. The changes will be effective for the 2026 and succeeding crop years for crops with a contract change date on or after 11/30/2025. For all other crops, the changes to the policies made in the final rule are applicable for the 2027 and succeeding crop years. The final rule is effective 11/30/2025. FCIC will accept comments until 01/27/2026. The final rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-11-28/pdf/2025-21482.pdf. Federal Register, Vol. 90, No. 227, 11/28/2025, 54523-54544.

CFTC Amends Rules of Practice and Investigations.

The Commodity Futures Trading Commission (CFTC) issued a final rule to amend its Rules of Practice and its Rules Page 20 | December 2025

Regulatory Spotlight Relating to Investigations. The revised Rules of Practice enhance the transparency of CFTC’s enforcement proceedings.

The revised Rules Relating to Investigations revise applicable procedures to notify persons who may be named in an enforcement action. The final rule is effective 12/03/2025. The final rule may be viewed at: https://www.govinfo.gov/ content/pkg/FR-2025-12-03/pdf/2025-21888.pdf. Federal Register, Vol. 90, No. 230, 12/03/2025, 55642-55646.

NCUA Seeks Comment on Fidelity Bond and Insurance Coverage Information Collection.

The National Credit Union Administration (NCUA) seeks comment regarding an information collection titled, Fidelity Bond and Insurance Coverage. The Federal Credit Union Act requires that boards of federal credit unions (FCU) arrange for adequate fidelity coverage for officers and employees having custody of or responsibility for handling funds. The regulation contains reporting requirements where a credit union seeks to exercise flexibility under the regulations.

Comments are due 12/17/2025. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2025-11-17/ pdf/2025-20005.pdf. Federal Register, Vol. 90, No. 219, 11/17/2025, 51411.

Compliance Notes OCC confirmed permissible bank activities related to riskless principal transactions in crypto-assets. In particular, OCC confirmed that a national bank may engage in riskless principal crypto-asset transactions as part of the business of banking. Such transactions involve a bank acting as principal in a crypto-asset transaction with one customer while simultaneously entering into an offsetting transaction with another customer. The bank serves as an intermediary and does not hold the crypto-assets in inventory, instead acting in a capacity equivalent to that of a broker acting as agent.

The interpretive letter may be viewed at: https://www.occ.gov/news-issuances/news-releases/2025/nr-occ-2025-121. html FBI issued an Alert to warn of cyber criminals impersonating financial institutions to steal money or information in Account Takeover (ATO) fraud schemes. The cyber criminals target individuals, businesses, and organizations of varied sizes and across sectors. In ATO fraud, cyber criminals gain unauthorized access to the targeted online financial institution, payroll, or health savings account, with the goal of stealing money or information for personal gain. Since January 2025, the FBI Internet Crime Complaint Center received more than 5,100 complaints reporting ATO fraud, with losses exceeding $262 million. The alert may be viewed at: https://www.ic3.gov/PSA/2025/PSA251125 FRB released its semiannual Supervision and Regulation Report for 2025. The report focuses on developments in banking system conditions, regulatory developments, and supervisory developments. In the banking system conditions section of the report, FRB provides an overview of the financial condition of the banking sector, outlines its recent regulatory policy, and provides highlights of FRB’s current supervisory programs and priorities. The report may be viewed at: https://www.federalreserve.gov/publications/files/202512-supervision-and-regulation-report.pdf FHFA announced the conforming loan limit values (CLLs) for mortgages Fannie Mae and Freddie Mac will acquire in 2026. In most of the U.S., the 2026 CLL value for one-unit properties will be $832,750, an increase of $26,250 from 2025. For areas in which 115 percent of the local median home value exceeds the baseline conforming loan limit value, the applicable loan limit will be higher than the baseline loan limit. The Housing and Economic Recovery Act establishes the high-cost area limit in those areas as a multiple of the area median home value, while setting the ceiling at 150 percent of the baseline limit. Median home values generally increased in high-cost areas in 2025, which increased their CLL values. The new ceiling loan limit for one-unit properties will be $1,249,125, which is 150 percent of $832,750.

Special statutory provisions establish different loan limits for Alaska, Hawaii, Guam, and the U.S. Virgin Islands. In these areas, the baseline loan limit and the ceiling loan limit for one-unit properties will be $1,249,125 and $1,873,675, respectively. Due to rising home values, the CLL values will be higher in all but 32 U.S. counties or county equivalents.

The announcement may be viewed at: https://www.fhfa.gov/news/news-release/fhfa-announces-conforming-loan-limitvalues-for-2026

December 2025 | Page 21

Compliance Notes OCC and FDIC rescinded the 2013 Interagency Guidance on Leveraged Lending, and a corresponding 2014 FAQ for implementing the guidance. The agencies expect banks to manage leveraged exposures consistent with general principles for safe and sound lending. The announcement may be viewed at: https://www.occ.gov/news-issuances/newsreleases/2025/nr-ia-2025-119.html FinCEN issued a financial trend analysis on ransomware incidents in BSA data between 2022 and 2024. The amount totaled more than $2.1 billion in ransomware payments. More information about the analysis may be viewed at: https://www.fincen.gov/news/news-releases/fincen-issues-financial-trend-analysis-ransomware OCC updated guidance that applies to commercial loans to companies in an early, expansion, or late stage of corporate development. The bulletin refers to the loans as “venture loans.” The updated bulletin is meant to provide transparency into OCC’s supervisory approach and application of existing laws, regulations, and guidance. The updated guidance may be viewed at: https://www.occ.gov/news-issuances/bulletins/2025/bulletin-2025-45.html Treasury announced guidance on new tax benefits for HSA participants under the One Big Beautiful Bill Act. The changes expand HSA eligibility. The guidance may be viewed at: https://www.irs.gov/newsroom/treasury-irs-provideguidance-on-new-tax-benefits-for-health-savings-account-participants-under-the-one-big-beautiful-bill OCC releases its Semiannual Risk Perspective for Fall 2025. The report highlights credit, market, operational, and compliance risks. The report reflects data as of 06/30/2025, unless otherwise indicated. The report may be viewed at: https://www.occ.gov/publications-and-resources/publications/semiannual-risk-perspective/files/pub-semiannual-riskperspective-fall-2025.pdf OCC released preliminary findings from its supervisory review of debanking activities at the nine largest national banks it supervises. OCC conducted the review in accordance with Executive Order, Guaranteeing Fair Banking for All Americans, to determine whether the institutions debanked or discriminated against any customer or potential customer on the basis of their political or religious believes or lawful business activities. The report may be viewed at: https://www. occ.gov/news-issuances/news-releases/2025/nr-occ-2025-123.html President Trump issued an Executive Order which sets forth a framework to forbid State laws that conflict with a national policy for AI. The executive order titled, Ensuring A National Policy Framework for Artificial Intelligence, may be viewed at: https://www.whitehouse.gov/presidential-actions/2025/12/eliminating-state-law-obstruction-of-nationalartificial-intelligence-policy/ OCC confirmed permissible bank activities related to riskless principal transactions in crypto-assets. In particular, OCC confirmed that a national bank may engage in riskless principal crypto-asset transactions as part of the business of Offers 100% Online Banking Certificatetransaction for Working banking.UW-Whitewater Such transactions involve a bank acting as principal in a crypto-asset with Professionals one customer while simultaneously entering into an offsetting transaction with another customer. The bank serves as an intermediary and Bankers across Wisconsin now have an avenue sharpen industry knowledge andofadvance careers does not hold the crypto-assets in inventory, insteadtoacting in atheir capacity equivalent to that a brokertheir acting as agent. the University Banking Certificate for Banking Professionals. This program is a Thethrough interpretive letter mayof beWisconsin–Whitewater’s viewed at: https://www.occ.gov/news-issuances/news-releases/2025/nr-occ-2025-121.

12-credit, fully online opportunity offered through the College of Business and Economics. html The certificate is designed specifically for individuals already working in financial services. The courses help -FBIprofessionals issued an Alert to warn cyber criminalsofimpersonating financial institutions to steal money or that information deepen theirofunderstanding core banking concepts while building practical skills will serve in Account Takeoverwork.

(ATO)Coursework fraud schemes.

The cyber targetRegulation individuals, businesses, andand organizations of their day-to-day includes Bank criminals Management, and Compliance, Credit Analysis varied sizes and across sectors. In ATO fraud, cyber criminals gain unauthorized access to the targeted online financial — all institution, payroll, orwith health savings account, with the goal of stealing money or information for personal gain. Since taught by faculty industry expertise.

January 2025, the FBI Internet Crime Complaint Center received more than 5,100career. complaints reporting fraud, with The program is open to all professionals at every stage of their banking No prior collegeATO experience losses exceeding $262 million.

The alert may be viewed at: https://www.ic3.gov/PSA/2025/PSA251125 is required, and applicants may enroll as Special No Credential (SNC) students without submitting transcripts.

Students usually take one to two courses per term, allowing them to balance education with full-time employment.

-FRB released its semiannual Supervision and Regulation Report for 2025. The report focuses on developments in UW-Whitewater’s online certificate program offers an accessible path for working individuals interested in banking system conditions, regulatory developments, and supervisory developments. In the banking system conditions expanding their foundation in bank operations or preparing for future leadership. section of the report, FRB provides an overview of the financial condition of the banking sector, outlines its recent Admission is currently open. Visit https://www.uww.edu/online/certificates/banking for more information. regulatory policy, and provides highlights of FRB’s current supervisory programs and priorities. The report may be viewed at: https://www.federalreserve.gov/publications/files/202512-supervision-and-regulation-report.pdf

Page 22 | December 2025

CLE Hours 2024 and 2025 List of Recent WBA Programs to Receive Continuing Legal Education Designation Wisconsin Bank Attorney: The Board of Bar Examiners of the Supreme Court of Wisconsin has approved the following completed WBA educational programs for use toward the Wisconsin mandatory Continuing Legal Education (CLE) requirement for attorneys. None of the activities listed below include Ethics and Professional Responsibility (EPR) hours or qualify for GAL education.

2024 WBA Compliance Forum, Februrary 2024 3.0 CLE Hours February 20, 2024 – Wisconsin Dells

WBA Compliance Forum, June 2024 3.5 CLE Hours June 25, 2024 – Wisconsin Dells

WBA Trust Conference, May 2024 3.5 CLE Hours May 23, 2024 – Madison

WBA Compliance Forum, November 2024 3.5 CLE Hours November 5, 2024 – Wisconsin Dells

2025 WBA Trust Conference, May 2025 2.0 CLE Hours May 22, 2025 – Madison

WBA Compliance Forum, November 2025 3.0 CLE Hours November 4, 2025 – Wisconsin Dells

WBA Compliance Forum, June 2025 3.5 CLE Hours June 17, 2025 – Stevens Point

Mark Your Calendars WBA Capitol Day | February 11, 2026 | Madison

December 2025 | Page 23

January 14

March continued

Midwest Economic Forecast Forum

18-19

Virtual – multiple registration options available 1/81/30 9

Understanding Bank Performance Virtual Series Eight-part webinar series – $1,000/attendee

Online Workshop: Credit Analysis Basics Virtual full day – $275/attendee

20

Community Bankers for Compliance – Session I

29

Branch Manager Boot Camp: Session I

TBD

Fraud On-Demand Video Series

February Wisconsin Dells 11

Capitol Day Madison

11 17

Information Security Officer Workshop Online Workshop: Fundamentals of Commercial Lending 101

April

Branch Manager Boot Camp: Session II

Eight-part webinar series – $1,000/attendee Fond du Lac - $550/attendee

14-16

Real Estate Compliance School Madison or Virtual - $895/attendee

15

Online Workshop: Basic Personal & Business Tax Return Analysis Virtual full day – $275/attendee

16-17

Agricultural Bankers Conference Wisconsin Dells - $350/attendee

20-25

Principles of Banking

9th Annual Power of Community Week www.wisbank.com/BanksPowerWI

20-24

School of Bank Management Madison - $1,395/attendee

21

Community Bankers for Compliance – Session II Virtual half-day – annual membership/pricing varies

ABA/WBA Washington Summit Washington, DC

Advanced IRA Workshop Madison or Virtual - $275/attendee

11

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

Online Workshop: Wowing the Client!

March 10

Four-part series, virtual half days – $900/attendee

Principles of Banking

Compliance Forum: Session III

Four-part series, virtual half days – $900/attendee

9-11

Branch Manager Boot Camp: Session III

8-9

Madison - $550/attendee 26

Wisconsin Dells - $275/attendee 26

Virtual full day – $275/attendee

Virtual half-day – $300/attendee 25-26

Security Officer Workshop

Understanding Bank Performance Virtual Series

Virtual full day – $275/attendee 25

Virtual full day – $275/attendee 26

4/24/24

Wisconsin Dells – $275/attendee 25

Online Workshop: Fundamentals of Comm.

Lending 201: Analyzing Repayment Sources

Online Workshop: Key Ratio Analysis

Wisconsin Dells – annual membership/pricing varies 24

Residential Mortgage Lending School Madison - $1,095/attendee

25

TBD

Bank Executives Conference

Loan Compliance School Madison or Virtual - $895/attendee

23-26

Virtual half-day – $1,700 membership/1 attendee

Five-part video series – $995/bank

4-6

Wausau – $550/attendee 17-19

st

Four-part series, virtual half days – $900/attendee

Supervisor Boot Camp

Health Savings Accounts (HSA) Workshop Madison or Virtual - $275/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.

Schools/Boot Camps – Focused on a particular area of banking, allowing for a deep dive into that focused area over the course of two to six days.

Workshops/Seminars – One-day programs focused on a specific topic or

11-12

Call Report Workshop Two Virtual Half-Days - $295/attendee

area of banking.

3/125/9

Virtual Credit Analyst Development Program

WBA-Hosted Webinars

Six-part online workshop series – $2,750/attendee

Other Events

www.wisbank.com | 608-441-1252 | wbaeducation@wisbank.com Page 24 | December 2025