May 2026
Special Focus
2025-2026 State Legislative Update (Part 2)
The March Compliance Journal included a special focus article which provided an update on the 2025-2026 Wisconsin legislative session (Part 1). As was discussed in that article, the most active portion of the session has come to a close. However, the biennial legislative term does not formally end until January 4, 2027. During the time since the release of Part 1, additional bills have been signed into law. This article presents a summary of new laws which vary from directly to indirectly relevant to the banking industry.
Most of the laws summarized below have been provided for information purposes and should not require action from banks. However, two are of note. First, WBA-supported legislation related to virtual currency kiosks was signed into law. Second, a new law expands the rights of patient representatives to authorize certain expenditures of incapacitated individuals. These two laws are presented at the beginning of this article. The remaining laws are presented in order of perceived relevance and include some notable items such as reorganization of law governing recordings with register of deeds and high school personal financial literacy requirements.
New Laws Passed This Session Since Part 1
Virtual Currency Kiosks
As discussed in Part 1, a bill was introduced this session designed to regulate virtual currency kiosks. These kiosks appear at many locations across the state and have been increasingly utilized for fraudulent transactions. WBA supported legislation designed to reduce fraud through the use of these kiosks. Specifically, provisions were incorporated into the bill to establish daily transaction limits and require refunds of fraudulent transactions. Since writing of Part 1, the bill regulating virtual currency kiosks was signed into law as 2025 Wisconsin Act 226 and includes those provisions supported by WBA.
Among other things, Act 226 requires all virtual currency kiosk operators (operators) to be licensed under state financial laws and creates consumer protection and antifraud measures aimed at reducing the extent of ongoing cryptocurrency-related scams. It also requires fraud warnings on the front of the kiosk, among other protections. One protection in particular creates a daily transaction limit whereby an operator may not accept from or dispense to a customer, by any means of any virtual currency kiosk, more than $1,000 in fiat currency in the same day. Another protection requires operators to refund the customer, upon request of the customer, the full amount of any transaction, including any fees charged in connection with the transaction, if, not later than 30 days after the transaction, the customer contacted the operator, the Department of Justice, Department of Financial Institutions, or a law enforcement agency to inform them of the fraudulent nature of the transaction. Operators must also provide live, toll-free customer service during all hours in which the virtual currency kiosk is operable, provide physical and electronic detailed transaction receipts, and maintain a written antifraud policy.
WBA is pleased to report this success in the industry’s ongoing efforts to combat fraud. Act 226 is generally effective April 10, 2026; however, the customer identification requirements are delayed by sixty days to allow for creation and implementation of those provisions.
Patient’s Representative
Another notable banking-relevant law passed since Part 1 is Act 115. Act 115 allows certain individuals to consent
Special Focus
to post-hospital care admissions for incapacitated individuals without first obtaining guardianship. The law was passed in order to reduce unnecessary hospital stays and delays in care transitions, particularly where it was untimely to obtain guardianship in relation to obtaining the necessary care for an incapacitated individual. Under the new law, some individuals, such as a patient’s representative, now have the authority to authorize expenditures related to health care to the same extent as a guardian of the estate, unless the incapacitated individual has an agent under a financial POA who is authorized to make expenditures for health care. The procedure for obtaining this authority, and the exercise of it, is up to the individual. The Wisconsin Department of Health Services (DHS) is currently in the process of creating procedures, forms, and training related to the new law. WBA has been in conversations with DHS, who anticipates having implementation prepared by July 1, 2026.
The most significant provisions of Act 115 are effective June 1, 2026. Banks may be presented with requests by patient representatives to transact on accounts of incapacitated customers. These requests will need to be reviewed to confirm whether the patient representative has proper authority. While not yet available, DHS is currently designing forms related to the authority of patient representatives. WBA will continue to provide updates as more information becomes available.
Register of Deeds
2025 Wisconsin Act 234 reorganizes law governing registers of deeds and real property recordings. It clarifies terminology by consistently replacing “instrument” with “document,” consolidates redundant provisions, and reorganizes duties, fee structures, and indexing requirements. Notably, it provides statutory authority for registers of deeds to refuse documents that materially impair accurate recording, indexing, or reproduction. It also clarifies and provides more explicit requirements for legal descriptions, among other changes.
While Act 234 does not make any explicit legal changes to recording procedures, the clarifications give register of deeds clearer authority to reject documents that do not comply with standard format requirements for recording documents under Wis. Stat. sec. 59.43.
To help prevent fraudulent recordings, Act 234 also prohibits register of deeds from recording certain types of documents unless they contain document numbers for previously recorded documents; recording a document that contains a scrivener’s error, unless the error is clearly marked and initialed; recording certain court documents without a clerk of court certification; or recording a document that the register of deeds determines is not authorized to be recorded or that is being recorded for an unauthorized purpose. It is now also a crime, punishable as a Class I felony, to knowingly provide a forged document for recording. Act 234 is effective April 10, 2026.
High School Personal Financial Literacy Requirement
Another win for the industry this session is related to the ability of banks to assist students in meeting financial literacy requirements for graduation. For context, in 2024, Wisconsin passed a WBA-supported law that high school students complete at least 0.5 credits of personal financial literacy that includes financial mindset, education and employment, money management, saving and investing, credit and debt, and risk management and insurance. As a follow-up to that, Act 223 clarifies that the graduation requirement may be met by a pupil who successfully completes a financial literacy program offered by a financial institution through a branch located in a school if the school board determines the program satisfies the personal financial literacy requirement under Wis. Stat. sec. 118.33(1)(a)1.f. Act 223 is effective April 10, 2026.
May 2026
Volume 31, Number 11
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 Emily Torgerson
Copyright ©2026
Wisconsin Bankers Association. All rights reserved. Reproduction by any means of the entire contents or any portion of this publication without prior written permission is strictly prohibited. This publication is intended to provide accurate information in regard to the subject matter covered as of the date of publication; however, the information does not constitute legal advice. If legal advice or other expert assistance is required, the services of a competent and professional person should be sought.
Special Focus
Independence Accounts
Act 225 creates new features related to independence accounts. An independence account is a savings account approved by DHS. These accounts existed prior to Act 225, but the new law changes how funds are treated in such accounts for purposes of DHS’ program eligibility requirements. Specifically, DHS must exclude up to $40,000 in inherited assets when determining countable assets under existing eligibility rules. The law creates no monitoring or reporting requirements for banks. Administration of the program, eligibility criteria, registration, and approval of such accounts remains handled by DHS. Act 225 is effective April 10, 2026.
WHEDA Housing Programs
Act 237 modifies the Infrastructure Access Loan Program, Restore Main Street Loan Program, and Commercial-toHousing Conversion Loan Program as administered by the Wisconsin Housing and Economic Development Authority (WHEDA). It expands eligibility to include tribal housing authorities, revises definitions of developers and governmental units, and streamlines program requirements. It implements cost-reduction measures by local governments by requiring documentation of zoning, regulatory, and fee changes designed to reduce housing costs.
The law increases maximum loan percentages and dollar limits across multiple programs, allows lower or zero interest rates, and updates security and guarantee requirements. Workforce and senior housing supported by these loans must generally remain restricted for ten years, with resale price and occupancy limits recorded as deed restrictions. Act 237 attempts to clarify that the purchaser-income requirements of the workforce and senior housing programs do not apply to any sale that occurs after the initial owner-occupier’s purchase. Finally, the Act updates real estate disclosure forms to require sellers to disclose restrictive covenants or deed restrictions tied to WHEDA-funded developments. Most provisions of Act 237 are effective April 10, 2026. The changes made to real estate related disclosure forms under the programs are effective January 1, 2026.
Workforce Home Loan Program
2025 Wisconsin Act 239 creates a workforce home loan revolving loan program administered by WHEDA. The program is designed to support first-time homebuyers purchasing new construction homes by establishing a dedicated workforce home loan fund, financed in part by transfers from existing housing revolving loan funds, with authority to allocate up to $10 million. Eligible applicants must not have owned residential real property for three consecutive years and have an annual household income at or below 100 percent of area median income and meet underwriting, credit, and housing counseling requirements. Loans are interest-free, capped at the lesser of $60,000 or 25 percent of the home purchase price or fair market value of the home, and are secured as second mortgages. Repayment terms vary by income level, including deferred repayment options for lower-income households. The program prioritizes gap financing, sets aside funding for rural areas, and sunsets June 30, 2031. Act 239 is effective April 10, 2026.
Additional Changes to Vehicle Classifications
As discussed in Part 1, Wisconsin passed new laws related to the treatment of certain vehicles. While the changes generally do not have a direct impact on a vehicle as collateral, WBA found that the changes were still worth tracking and reporting on for purposes of awareness. For example, the changes may present implications for loan customers with all-terrain vehicles (ATVs), utility terrain vehicles (UTVs), off-highway motorcycles, and snowmobiles, which are helpful for lenders to be aware of in their customer relationships. Since writing of Part 1, an additional law included within this scope became effective.
2025 Wisconsin Act 114 updates requirements related to the operation of ATVs, UTVs, off-highway motorcycles, and snowmobiles. Including, those involved in emergency and law- enforcement use. The law revises equipment requirements for such vehicles, including headlamps, tail lamps, brake lights, and maintenance standards and creates new definitions for patrol versions of these vehicles. Act 114 is effective March 22, 2026.
Similarly, Act 162 expands requirements for trailer registration for transporting a modular housing unit or other portable building to include the transport of manufactured housing units. Act 162 is effective April 4, 2026.
Special Focus
Sports Betting
2025 Wisconsin Act 247 defines certain event or sports wagers as excluded from the statutory definition of a “bet.” The new law applies to wagers made by individuals physically located in Wisconsin using electronic devices, when the wagering server is located on federally-recognized tribal lands in Wisconsin. The wagers must be conducted under an Indian gaming compact entered into before April 1, 1993, and are legally deemed to occur on those tribal lands. Act 247 is effective April 11, 2026.
Property Tax Exemption for Recreational Structures
Act 117, enacted March 27, 2026, creates a new property tax exemption for recreational prefabricated structures located in licensed campgrounds. The Act defines these structures as towable, temporary living units used for recreational or seasonal purposes, including related decks and sheds, when situated on land not owned by the structure’s owner. Beginning with assessments as of January 1, 2026, qualifying structures are exempt from property taxation. To offset lost local revenue, starting in 2027, the state will provide payments to taxing jurisdictions equal to the property taxes levied on these structures for the January 1, 2025 assessment year. While this should not impact bank lending operations, it may be indirectly relevant to those who have business relationships with those who own or are involved in covered structures, or local governments. Act 117 is effective March 29, 2026.
Neighborhood Improvement District Infrastructure Financing
Act 120 makes changes to municipal authority related to financing certain infrastructure by special assessment approved by neighborhood improvement districts (NID). A municipality may establish a NID if all affected real property owners petition for it, and the NID’s operating plan explicitly approves the special assessment. Proceeds must be used solely for residential development infrastructure and may be collected in installments through property tax rolls, even if not delinquent. The law also clarifies governance rules for NIDs with fewer than five property owners and provides that termination of a NID does not affect the enforceability of previously imposed assessments. It also updates Wisconsin’s real estate condition report forms to require disclosure of existing neighborhood improvement special assessments.
While Act 120 places no obligations on banks, it is worth being aware of from the perspective of understanding a municipality’s ability to create the new type of NID, how the proceeds of the special assessment may be used, of the impact on a borrower’s financial situation if subject to a special assessment, and to be mindful to review certain real estate condition reports for information regarding the special assessment. Act 120 is effective March 29, 2026, except the real estate condition report change does not apply to reports furnished before October 1, 2026.
Manure-Derived Fertilizer Labeling
Act 121 updates fertilizer requirements for products made from composted or vermicomposted manure. The law creates new definitions for “beneficial substances,” “vermicompost,” “typical analysis,” and “compost-based soil or plant additives.” Generally speaking, it relates to requirements for labels of certain fertilizers based upon their components. It also exempts manure-based compost fertilizers from minimum nutrient percentage requirements that apply to mixed fertilizers. Additional changes related to controlled field tests and analyses for compost-based products.
While banks are not required to monitor fertilizers, their components, or labels for these requirements, agricultural lenders may have customers for which the changes are relevant to. Act 121 is effective March 29, 2026.
Conclusion
This session saw progress in furthering the industry’s priorities to fight fraud with the passage of virtual currency kiosk law. WBA will continue to advocate on behalf of the industry for the remainder of this session and continue to monitor and report on any meaningful developments.
For more information about any of the 2025 Wisconsin Acts summarized in Part I or in this article, or for any other Act of the 2025-2026 legislative session, be sure to view the Wisconsin State Legislature website at: https://docs.legis. wisconsin.gov/2025/related/acts
Regulatory Spotlight
Agencies Issue Final CBLR Rule.
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) adopted a final rule that lowers the community bank leverage ratio (CBLR) requirement from 9 percent to 8 percent, consistent with the lower bound provided in section 201 of the Economic Growth, Regulatory Relief, and Consumer Protection Act. The final rule also extends the length of time that certain depository institutions and depository institution holding companies can remain in the CBLR framework while not meeting all of the qualifying criteria for the CBLR framework from two consecutive quarters to four consecutive quarters, subject to a limit of eight quarters in the previous five-year period. The final rule is effective 07/01/2026. The final rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-04-29/pdf/2026-08298.pdf. Federal Register, Vol. 91, No. 82, 04/29/2026, 22973-22989.
CFPB Amends Disparate Impact Provisions of Regulation B.
The Bureau of Consumer Financial Protection (CFPB) issued a final 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 facilitate compliance with ECOA by clarifying the obligations imposed by statute. The final rule is effective 07/21/2026. The final rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-04-22/pdf/2026-07804.pdf Federal Register, Vol. 91, No. 77, 04/22/2026, 21620-21670.
CFPB Issues Final Section 1071 Rule.
CFPB issued a final rule to revise certain provisions of Regulation B, subpart B, which implements changes to the Equal Credit Opportunity Act made by section 1071 of the Dodd-Frank Act. CFPB has amended 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 changes will streamline the rule, reduce complexity for lenders, improve data quality, and advance the purposes of section 1071. The final rule is effective 06/30/2026. The compliance date for the rule is 01/01/2028. The final rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-05-01/ pdf/2026-08494.pdf. Federal Register, Vol. 91, No. 84, 05/01/2026, 23530-23626.
Regulatory Spotlight
FDIC Announces Receivership Termination.
The Federal Deposit Insurance Corporation (FDIC or Receiver), as Receiver for the insured depository institution listed in the notice, was charged with the duty of winding up the affairs of the former institution and liquidating all related assets. The Receiver has fulfilled its obligations and made all dividend distributions required by law. The Receiver has further irrevocably authorized and appointed FDIC-Corporate as its attorney-in-fact to execute and file any and all documents that may be required to be executed by the Receiver which FDIC-Corporate, in its sole discretion, deems necessary, including but not limited to releases, discharges, satisfactions, endorsements, assignments, and deeds. Effective on the termination date listed in the notice, the receivership has been terminated, the Receiver has been discharged, and the receivership has ceased to exist as a legal entity. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR2026-05-06/pdf/2026-08792.pdf Federal Register, Vol. 91, No. 87, 05/06/2025, 24543.
FDIC Announces Intent to Terminate Receiverships.
FDIC, as Receiver for the institutions listed in the notice, announced it intends to terminate its receivership for said institutions. The liquidation of the assets for each receivership has been completed. To the extent permitted by available funds and in accordance with law, the Receiver will be making a final dividend payment to proven creditors. Based upon the foregoing, the Receiver has determined that the continued existence of the receiverships will serve no useful purpose. Consequently, notice is given that the receiverships shall be terminated, to be effective no sooner than thirty days after the date of the notice. If any person wishes to comment concerning the termination of any of the receiverships, such comment must be made in writing, identify the receivership to which the comment pertains, and be sent within thirty days of the date of the notice to the addressed listed in the notice. No comments concerning the termination of the mentioned receiverships will be considered which are not sent within this timeframe. The notice may be viewed at: https:// www.govinfo.gov/content/pkg/FR-2026-05-06/pdf/2026-08793.pdf Federal Register, Vol. 91, No. 87, 05/06/2026, 24543.
FDIC Updates Listing of Financial Institutions in Liquidation.
Notice is hereby given that FDIC has been appointed the sole receiver for the financial institution listed in the notice effective as of the “Date Closed” as indicated in the notice. The list (as updated from time to time in the Federal Register) may be relied upon as ‘‘of record’’ notice that FDIC has been appointed receiver for purposes of the statement of policy published in the July 2, 1992, issue of the Federal Register. For further information concerning the identification of any institutions that have been placed in liquidation, please contact FDIC at the addresses provided in the notice. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-05-07/pdf/2026-09064.pdf. Federal Register, Vol. 91, No. 88, 05/07/2026, 24867.
FDIC Seeks Comment on Information Collections.
FDIC seeks comment regarding the following two information collections Notification of Performance of Bank Services; and Treatment by FDIC as Conservator or Receiver of Financial Assets Transferred by an Insured Depository Institution in Connection With a Securitization or Participation After September 30, 2010. The purpose of each information collection is discussed in the notice. Comments are due 06/22/2026. The notice may be viewed at: https://www.govinfo.gov/ content/pkg/FR-2026-04-21/pdf/2026-07749.pdf Federal Register, Vol. 91, No. 76, 04/21/2026, 21290-21291.
FDIC seeks comment regarding an information collection titled, Fast-Track Generic Clearance for the Collection of Qualitative Feedback. The information collection establishes ongoing authority for FDIC to conduct yet-to-be-determined occasional quality of service surveys under the Office of Management and Budget’s generic survey program. Comments are due 06/22/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-04-23/pdf/202607920.pdf Federal Register, Vol. 91, No. 78, 04/23/2026, 21819-21820.
OCC Issues Interim Final Rule on National Bank Non-Interest Charges and Fees.
The Office of the Comptroller of the Currency (OCC) adopted an interim final rule to clarify that national banks’ power to charge non-interest charges and fees includes the power to assess, collect, impose, levy, receive, reserve, take, or otherwise obtain non-interest charges and fees, including interchange fees from credit and debit card operations. Further, the interim final rule explains that national banks may charge non-interest charges or fees, even when such charges and
Regulatory Spotlight
fees are set by or in consultation with third parties. The interim final rule is effective 06/30/2026. Comments are due 05/29/2026. The interim final rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-04-29/pdf/202608328.pdf Federal Register, Vol. 91, No. 82, 04/29/2026, 22989-22995.
OCC Issues Interim Final Order Preempting the Illinois Interchange Fee Prohibition Act.
OCC issued an interim final order concluding that Federal law preempts the Illinois Interchange Fee Prohibition Act, which purports to prohibit national banks and Federal savings associations from charging or receiving interchange fees on the tax and gratuity portions of payment card transactions; and restrict the use of payment card transaction data. The interim final order is effective 06/30/2026. Comments on the interim final order are due 05/29/2026. The interim final order may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-04-29/pdf/2026-08341.pdf Federal Register, Vol. 91, No. 82, 04/29/2026, 23150-23158.
OCC Seeks Comment on Proposal to Streamline Regulations Concerning Public Welfare Investments, Open Market Collateralized Loan Obligations, and Nondiscrimination Requirements.
OCC issued a proposed rule to rescind or amend certain regulations that are unnecessary or lack clear statutory authority, consistent with the criteria set out in the Executive Order titled Ensuring Lawful Governance and Implementing the President’s “Department of Government Efficiency” Deregulatory Initiative. The proposed rule would remove certain references to minority- and women-owned entities; remove the portion of the credit risk retention requirements that provides an alternative compliance option for lead arrangers of open market collateralized loan obligations; and remove certain duplicative non-discrimination requirements for Federal savings associations. Comments are due 05/27/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-04-27/ pdf/2026-08143.pdf Federal Register, Vol. 91, No. 80, 04/27/2026, 22481-22485.
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OCC Seeks Comment on Information Collections.
OCC seeks comment regarding an information collection titled, Retail Foreign Exchange Transactions. The OCC’s rule pertaining to retail foreign exchange transactions (12 CFR part 48) allows national banks and Federal savings associations to offer or enter into retail foreign exchange transactions. In order to engage in the transactions, institutions must comply with various reporting, disclosure, and recordkeeping requirements included in that rule. The information collection is used to collect the information required under part 48. Comments are due 05/20/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-04-20/pdf/2026-07664.pdf Federal Register, Vol. 91, No. 75, 04/20/2026, 21080-21081.
OCC seeks comment regarding an information collection titled, Assessment of Fees. OCC uses the information collected to calculate the assessment for each independent credit card institution and adjust the assessment rate for independent credit card institutions over time. Comments are due 05/26/2026. The notice may be viewed at: https://www.govinfo. gov/content/pkg/FR-2026-04-24/pdf/2026-07991.pdf Federal Register, Vol. 91, No. 79, 04/24/2026, 22224-22225.
OCC seeks comment regarding an information collection titled, Reporting, Recordkeeping, and Disclosure Requirements Associated with Proprietary Trading and Certain Interests in and Relationships with Covered Funds. The Bank Holding Company (BHC) Act generally prohibits any banking entity from engaging in proprietary trading or from acquiring or retaining an ownership interest in, sponsoring, or having certain relationships with a hedge fund or private equity fund (covered fund), subject to certain exemptions. The exemptions allow certain types of permissible trading and covered fund activities. The reporting, recordkeeping, and disclosure requirements associated with the rule permit banking entities and OCC to enforce compliance with the BHC Act. Comments are due 06/01/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-04-30/pdf/2026-08405.pdf. Federal Register, Vol. 91, No. 83, 04/30/2026, 23345-23346.
OCC seeks comment regarding an information collection titled, Recordkeeping Requirements for Securities Transactions. The information collection requirements in 12 CFR parts 12 and 151 are designed to ensure that national banks and Federal savings associations comply with securities laws and improve protections afforded to persons who purchase and sell securities through the financial institutions. OCC uses the required information in the course of its examinations to evaluate, among other things, an institution’s compliance with the antifraud provisions of the Federal securities laws.
Regulatory Spotlight
Comments are due 06/01/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-04-30/ pdf/2026-08444.pdf. Federal Register, Vol. 91, No 83, 04/30/2026, 23346-23348.
HUD Delays Effective Date of HOME Investment Partnerships Program Updates and Reopens Comment Period.
The Department of Housing and Urban Development (HUD) announced the delay of the effective date of its 01/06/2025, final rule for all provisions not currently in effect, until the publication of an additional final rule. The effective date for amendatory instruction 3 (revising 24 CFR 92.250) of the rule published in the Federal Register 04/17/2025, which was delayed 10/22/2025, is delayed indefinitely. Amendatory instruction 27 (revising 24 CFR 92.253) published in the Federal Register 01/06/2025, which was delayed 02/03/2025, and subsequently delayed 04/17/2025, and 10/22/2025, is delayed indefinitely. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-04-29/pdf/202608339.pdf Federal Register, Vol. 91, No. 82, 04/29/2026, 23014-23015.
HUD re-opened the comment period for certain topics and provisions that were addressed in its 05/29/2024, proposed rule titled, HOME Investment Partnerships Program: Program Updates and Streamlining. HUD has proposed to revise or revoke previously-proposed tenant protection provisions permitting participating jurisdictions to exceed the maximum per-unit subsidy for projects that met certain green building standards. The proposed rule would also create additional flexibilities related to scattered site manufactured housing rental projects. Comments are due 06/01/2026. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-04-30/pdf/2026-08406.pdf Federal Register, Vol. 91, No. 83, 04/30/2026, 23194-23204.
HUD Announces Annual Indexing of Basic Statutory Mortgage Limits for Multifamily Housing Programs.
HUD announced adjustments to the Basic Statutory Mortgage Limits for Multifamily Housing Programs for Calendar Year 2026. The adjustment of the dollar amounts is calculated using the percentage change in the Consumer Price Index for All Urban Consumers (CPI-U) as applied by the Board of Governors of the Federal Reserve System as described in the notice. The adjustments are effective 01/01/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/ FR-2026-05-06/pdf/2026-08795.pdf Federal Register, Vol. 91, No. 87, 05/06/2026, 24597-24598.
FEMA Issues Statewide per Capita Indicator for Recommending Cost Share Adjustment.
The Federal Emergency Management Agency (FEMA) announced that the statewide per capita indicator for recommending cost share adjustments for major disasters declared on or after 01/01/2026, through 12/31/2026, is $189. The notice applies to major disasters declared on or after 01/01/2026. The notice may be viewed at: https://www. govinfo.gov/content/pkg/FR-2026-04-28/pdf/2026-08224.pdf Federal Register, Vol. 91, No. 81, 04/28/2026, 22844.
FEMA Announces FY 2027 Financial Assistance/Subsidy Arrangement for Private Insurers.
FEMA announced the Fiscal Year (FY) 2027 Financial Assistance/Subsidy Arrangement (Arrangement) for private property insurers interested in participating in the National Flood Insurance Program’s Write Your Own (WYO) Program. FEMA is authorized to establish and carry out a National Flood Insurance Program (NFIP) to enable interested persons to purchase flood insurance. FEMA may use insurance companies and other insurers, insurance agents and brokers, and insurance adjustment organizations as fiscal agents of the United States to help it carry out the NFIP. FEMA may enter into contracts, agreements, or other appropriate arrangements with private insurance companies to use their facilities and services in administering the NFIP on such terms and conditions as they agree upon. FEMA enters into a standard Arrangement with private sector property insurers, also known as WYO companies, to sell NFIP flood insurance policies under their own names and adjust and pay claims arising under the Standard Flood Insurance Policy. Interested insurers must submit intent to subscribe or re-subscribe to the Arrangement by 09/02/2026. The notice may be viewed at: https:// www.govinfo.gov/content/pkg/FR-2026-05-05/pdf/2026-08728.pdf Federal Register, Vol. 91, No. 86, 05/05/2026, 24262-24270.
Regulatory Spotlight
FEMA Issues Final Flood Hazard Determinations.
Flood 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 the communities in Michigan, as listed in the notice. 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 an effect in order to qualify or remain qualified for participation in FEMA’s National Flood Insurance Program (NFIP). The date of 06/23/2026, 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-202605-07/pdf/2026-09013.pdf Federal Register, Vol. 91, No. 88, 05/07/2026, 24907-24908.
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, 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-2026-05-07/pdf/2026-09014.pdf Federal Register, Vol. 91, No. 88, 05/07/2026, 24901-24904.
FEMA Announces Changes in Flood Hazard Determinations.
FEMA issued a notice which lists communities in the states of Indiana, Ohio, and Wisconsin, 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-2026-05-07/pdf/2026-09020.pdf Federal Register, Vol. 91, No. 88, 05/07/2026, 24904-24907.
FinCEN Seeks Comment on Form 107, Registration of Money Services Business.
As part of its continuing effort to reduce paperwork and respondent burden, the Financial Crimes Enforcement Network (FinCEN) seeks comment regarding FinCEN Form 107, Registration of Money Services Business. Under the regulations, money services businesses (MSBs) must register with FinCEN using FinCEN Form 107, renew their registration every two years, and maintain a list of their MSB agents, if applicable. Comments are due 06/29/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-04-30/pdf/2026-08363.pdf. Federal Register, Vol. 91, No. 83, 04/30/2026, 23348-23352.
Treasury Seeks Comment on Survey of Costs of AML/CFT Compliance.
The Department of the Treasury (Treasury) seeks comment regarding an information collection titled, Survey of the Costs of AML/CFT Compliance. The information collection seeks information on anti-money laundering/countering the financing of terrorism (AML/CFT) compliance costs and related topics via a survey. The survey is voluntary. The purpose of the survey is to better understand the cost of AML/CFT compliance by financial institutions subject to the Bank Secrecy Act and applicable implementing regulations. Comments are due 05/28/2026. The notice may be viewed at: https://www.
Regulatory Spotlight
govinfo.gov/content/pkg/FR-2026-04-28/pdf/2026-08242.pdf Federal Register, Vol. 91, No. 81, 04/28/2026, 2291522916.
IRS Issues Final Rule on Occupations That Customarily and Regularly Received Tips.
The Internal Revenue Service (IRS) issued a final rule that identifies occupations that customarily and regularly received tips on or before 12/31/2024, and provides a definition of qualified tips for purposes of the income tax deduction for qualified tips. The final rule affects individuals who receive tips as part of their occupation. The final rule is effective 06/12/2026. The final rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-04-13/pdf/2026-07104. pdf. Federal Register, Vol. 91, No. 70, 04/13/2026, 19026-19056.
IRS Proposes Rule for Excise Tax on Remittance Transfers.
IRS issued a proposed rule that would provide rules and definitions related to the excise tax imposed on certain remittance transfers that occur after 12/31/2025. The proposed rule would affect certain remittance transfer providers and certain individuals sending remittance transfers. Comments are due 06/12/2026. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-04-13/pdf/2026-07085.pdf. Federal Register, Vol. 91, No. 70, 04/13/2026, 18797-18809.
IRS Seeks Comment on IRA and Trump Account Contribution Information.
IRS seeks comment regarding an information collection titled, IRA and Trump Account Contribution Information. Form 5498 is used by trustees and issuers to report contributions to, and the fair market value of, an individual retirement arrangement (IRA). The information on the form will be used by IRS to verify compliance with the reporting rules under regulation section 1.408-5 and to verify that the participant in the IRA has made the contribution that supports the deduction taken. The origination of the new Form 5498-TA is to comply with the requirements set forth in Public Law 119-21, Sec.70204 and IRC Section 530A(i) which established Trump Accounts and contribution pilot programs. Form 5498-TA reports contributions, rollovers, basis or investment in the contract, and the fair market value (FMV) of the account for the calendar year shown on the form and is furnished by the trustee of the Trump account. Comments are due 06/29/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-04-28/pdf/2026-08228. pdf Federal Register, Vol. 91, No. 81, 04/28/2026, 22914-22915.
SBA Seeks Comment on Information Collections.
The Small Business Administration (SBA) seeks comment regarding information collections titled, Prior Approval Surety Bond Surety Participation Agreement; and Preferred Surety Bond Surety Participation Agreement. The information collections are created for the purpose of surety bond company and surety bond agency participation in SBA’s Surety Bond Guarantee Program. The forms outline authorities granted by SBA to the signing business and the requirements of participation in the program as further described in the notice. Comments are due 05/13/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-04-13/pdf/2026-07113.pdf Federal Register, Vol. 91, No. 70, 04/13/2026, 18963-18964.
FSA Seeks Comment on Guaranteed Farm Loan Program.
The Farm Service Agency (FSA) seeks comment regarding an information collection titled, Farm Loan Programs, Guaranteed Farm Loan. The information is collected by the FSA loan official in consultation with participating lenders. The objective of the guaranteed loan program is to provide credit to applicants who are unable to obtain credit from lending institutions without a guarantee. The collected information is needed to make and service loans guaranteed by FSA to eligible farmers and ranchers by commercial lenders and nontraditional lenders. Comments are due 06/29/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-04-28/pdf/2026-08227.pdf Federal Register, Vol. 91, No. 81, 04/28/2026, 22788-22789.
FCA Proposes to Amend System Assessment Formula.
The Farm Credit Administration (FCA) issued a proposed rule to amend the regulations that implement provisions of the
Regulatory Spotlight
Farm Credit Act (Act) relating to assessments. The Act requires FCA to apportion the amount of assessments among the System institutions on a basis that FCA determines to be equitable. FCA proposed to revise the assessment formula to account for the size and structure of the System as it exists today and to bring the assessment formula closer to the degree of proportionality that existed when the rule became effective. The proposed changes would reapportion the total assessment among individual System banks and associations to further support cooperative and System principles. The proposed changes impact FCA’s current assessment of System banks and associations and do not impact FCA’s assessment of other System and non-System entities outlined in Part 607. The proposed changes also do not impact FCA’s annual administrative expenses or budget. Comments are due 06/22/2026. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-04-23/pdf/2026-07903.pdf Federal Register, Vol. 91, No. 78, 04/23/2026, 21734-21738.
RBC Announces Rescission of Funding for Rural Energy for America Program.
The Rural Business-Cooperative Service (RBC) issued a notice of funding opportunity (NOFO) in the Federal Register on 10/16/2024, to announce acceptance of grant, guaranteed loan, and combined grant and guaranteed loan applications under the Rural Energy for America Program (REAP). The NOFO was issued for Fiscal Years (FY) 2025, 2026, and 2027. RBC has rescinded the October 2024 NOFO. RBC is currently promulgating regulatory changes to the REAP program and available funding will be announced after publication of the changes. Rescission of the NOFO published in the Federal Register on 10/16/2024, is effective immediately. The notice may be viewed at: https://www.govinfo.gov/content/ pkg/FR-2026-04-15/pdf/2026-07332.pdf. Federal Register, Vol. 91, No. 72, 04/15/2026, 20090-20091.
RBC Seeks Comment on Rural Development Loan Servicing.
RBC seeks comment regarding an information collection titled, Rural Development Loan Servicing. The information collected is vital for RBC for prudent loan servicing, credit decisions, and reasonable program monitoring. Comments are due 06/22/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-04-22/pdf/2026-07842. pdf. Federal Register, Vol. 91, No. 77, 04/22/2026, 21398.
RHS Revises Calculations for Housing Programs.
The Rural Housing Service (RHS) issued a final rule to implement changes related to income calculation and net family assets for properties that receive funding from the Multi-Family Housing Section 515 Rural Rental Housing and the Section 514/516 Farm Labor Housing Direct Loan and Grant programs. The changes are intended to align RHS’ annual income certification requirements with the Housing Opportunity Through Modernization Act. The final rule is effective on 04/13/2026. The final rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-04-13/pdf/2026-07064. pdf Federal Register, Vol. 91, No. 70, 04/13/2026, 18769-18772.
RHS Changes Insurance Requirements for MFH Direct Loan and Grant Programs.
RHS issued a final rule to implement changes related to insurance requirements under the Multi-Family Housing (MFH) Direct Loan and Grant programs. The final rule will align Rural Development insurance coverage types, amounts, and deductibles with affordable housing industry standards to simplify the coverage amounts, deductible limits, and improve customer experience with updated and understandable insurance requirements. The final rule is effective 05/20/2026 The final rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-04-20/pdf/2026-07618.pdf Federal Register, Vol. 91, No. 75, 04/20/2026, 20863-20868.
RHS Issues Proposed Rule to Limit Party Concessions.
RHS issued a proposed rule to amend the current Single Family Housing Guaranteed Loan Program (SFHGLP) regulation to specify that real estate commission fees are excluded from interested party limitations. Comments are due 06/22/2026. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-04-20/pdf/202607617.pdf. Federal Register, Vol. 91, No. 75, 04/20/2026, 20941-20943.
FCC Issues Proposed Rule to Combat Illegal Robocalls.
The Federal Communications Commission (FCC) seeks comment on whether to adopt changes to its numbering policies with respect to how assigned numbering resources are utilized, reported, and resold by service providers as part of its continuing effort to combat illegal robocalls. FCC explores and proposes a broad array of solutions to strengthen its numbering requirements and policies, particularly as they relate to resellers that use numbering resources to engage in some of the most extensive illegal robocalling schemes. Comments are due 06/08/2026. Reply comments are due 07/07/2026. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-05-08/pdf/202609134.pdf. Federal Register, Vol. 91, No. 89, 05/08/2026, 25312-25325.
Agencies Propose Reporting Requirements for All Filers.
The Commodity Futures Trading Commission (CFTC) and Securities and Exchange Commission (SEC) (collectively, the agencies) have proposed to amend Form PF, the confidential reporting form for certain SEC-registered investment advisers to private funds, including those that also are registered with CFTC as a commodity pool operator or a commodity trading advisor. The proposed amendments would eliminate certain filing and reporting obligations, streamline certain requirements, and make corrections and other revisions. Comments are due 06/23/2026. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-04-24/pdf/2026-07993.pdf Federal Register, Vol. 91, No. 79, 04/24/2026, 22232-22391.
SEC Adopted Amendments to EDGAR Filer Manual.
The Securities and Exchange Commission (SEC) issued a final rule to adopt amendments to Volumes I and II of the Electronic Data Gathering, Analysis, and Retrieval system Filer Manual (EDGAR Filer Manual) and related rules and forms. The final rule is effective 04/16/2026. The final rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-202604-16/pdf/2026-07474.pdf Federal Register, Vol. 91, No. 73, 04/16/2026, 20335-20337.
SEC Adjusts Investment Advisors Act Dollar Amount Tests for Inflation.
SEC issued an order approving the adjustment for inflation of the dollar amount tests under the Investment Advisers Act. The order establishes the inflation adjusted dollar amount under management of the investment advisor to be considered a qualified client under the Investment Advisors Act exemption. The order may be viewed at: https://www.govinfo.gov/ content/pkg/FR-2026-05-01/pdf/2026-08480.pdf Federal Register, Vol. 91, No. 84, 05/01/2026, 23520-23521.
SEC Adopts Technical Amendments to Rules.
SEC issued a final rule to adopt technical amendments to correct an outdated cross-reference in its rules relating to locking and crossing quotations, and to correct an outdated cross-reference in its rules delegating authority to SEC staff to grant certain exemptions. The amendments are effective 05/05/2026. The final rule may be viewed at: https://www. govinfo.gov/content/pkg/FR-2026-05-05/pdf/2026-08721.pdf Federal Register, Vol. 91, No. 86, 05/05/2026, 2411524116.
SEC Proposes Amendments to Semiannual Reporting.
SEC proposed amendments to allow companies to file semiannual reports on new Form 10-S in lieu of quarterly reports on Form 10-Q to meet their interim reporting obligations under the Securities Exchange Act. SEC also proposed changes to the financial statement requirements of Regulation S-X to facilitate semiannual reporting and to simplify rules regarding the age of financial statements. Comments are due 07/06/2026. The proposed rule may be viewed at: https:// www.govinfo.gov/content/pkg/FR-2026-05-07/pdf/2026-09095.pdf. Federal Register, Vol. 91, No. 88, 05/07/2026, 24968-25058.
Regulatory Spotlight
SEC Seeks Comment on Concept Release on Consolidated Audit Trail, Other Audit Trails, and Data Sources.
SEC seeks comment in support of a comprehensive review of the Consolidated Audit Trail and other audit trails and related data sources currently used in the regulation of U.S. securities markets, including comments regarding the funding mechanisms for the audit trails and/or related data sources. There have been several developments since SEC last evaluated the scope and sufficiency of the audit trails and related data sources. The developments have prompted SEC to consider whether changes should be made to the rules and regulations governing existing audit trails and related data sources to better respond to and reflect current market conditions; demonstrated regulatory needs; civil liberty, privacy, and confidentiality concerns; cost-efficient technology solutions; and cybersecurity considerations. Comments are due 06/22/2026. The concept release may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-04-20/pdf/202607651.pdf. Federal Register, Vol. 91, No. 75, 04/20/2026, 20945-20968.
VA Seeks Comment on Information Collections.
The Department of Veterans Affairs (VA) seeks comment regarding an information collection titled, VA Loan Electronic Reporting Interface (VALERI) System and Title Requirements for Conveyance of Real Property. The information collection is used by VA in cases where loss mitigation efforts are unsuccessful and a VA-guaranteed loan goes into foreclosure. Comments are due 05/27/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-04-27/ pdf/2026-08166.pdf. Federal Register, Vol. 91, No. 80, 04/27/2026, 22586-22587.
VA seeks comment regarding an information collection titled, Non-supervised Lender’s Nomination and Recommendation of Credit Underwriter. The financial statement information collection is used to determine a borrower’s financial condition in connection with efforts to reinstate a seriously defaulted, guaranteed, insured, or portfolio loan. In addition, the information is used in determining the financial feasibility of a veteran or service member to obtain a home with the assistance of a Specially Adapted Housing Grant. Comments are due 06/03/2026. The notice may be viewed at: https:// www.govinfo.gov/content/pkg/FR-2026-05-04/pdf/2026-08620.pdf Federal Register, Vol. 91, No. 85, 05/04/2026, 24033-24034.
VA seeks comment regarding an information collection titled, VA-Guaranteed Home Loan Cash-Out Refinance Loan Comparison Disclosure. All-VA guaranteed cash-out refinancing loans must comply with 38 U.S.C. 3709 and 38 CFR 36.4306. All refinancing loan applications taken on or after the effective date that do not meet certain requirements may be subject to indemnification or the removal of the guaranty. Comments are due 06/08/2026. The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-05-07/pdf/2026-09049.pdf Federal Register, Vol. 91, No. 88, 05/07/2026, 24965.
NCUA
Proposes to Amend Regulations on
Merger of Insured Credit Unions into Banks.
The National Credit Union Administration (NCUA) issued a proposed rule to amend its regulations governing the merger of insured credit unions into banks. NCUA has proposed to eliminate certain prescriptive procedural, disclosure, and communication requirements. Comments are due 06/22/2026. The proposed rule may be viewed at: https://www.govinfo. gov/content/pkg/FR-2026-04-22/pdf/2026-07806.pdf Federal Register, Vol. 91, No. 77, 04/22/2026, 21391-21394.
NCUA Proposes to Amend Insurance Requirements.
NCUA issued a proposed rule to amend its regulations governing requirements for share insurance. The proposed rule would eliminate numerous provisions that merely point to substantive provisions codified elsewhere in NCUA’s regulations. The intended effect is to simplify the regulatory text and make it easier to navigate without altering the compliance obligations of federally insured credit unions. Comments are due 07/06/2026. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-05-07/pdf/2026-09010.pdf Federal Register, Vol. 91, No. 88, 05/07/2026, 24745-24748.
Regulatory Spotlight
NCUA Proposes to Increase Thresholds for the Major Assets Prohibition of the Depository Institution Management Interlocks Act Rule.
NCUA issued a proposed rule to increase two thresholds in its regulation implementing management official interlocks for purposes of the Depository Institution Management Interlocks Act (DIMIA). DIMIA provides that NCUA may adjust, by regulation, the major assets prohibition thresholds to allow for inflation or market changes. The proposal would increase both major assets prohibition thresholds to $10 billion to account for changes in the United States banking market since 1996. Additionally, the proposal would remove a presumption related to depository institutions controlled or managed by persons who are members of a minority group or women. Comments are due 07/06/2026. The proposed rule may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-05-07/pdf/2026-09009.pdf Federal Register, Vol. 91, No. 88, 05/07/2026, 24748-24752.
NCUA Seeks Comment on Revision to Call Report.
NCUA issued a request for information (RFI) on opportunities to enhance and streamline its data collections. The RFI covers data collected through the 5300 Call Report (Call Report), 5310 Corporate Credit Union Call Report (Corporate Call Report), and Form 4501A Profile (Profile). NCUA seeks feedback on the key challenges faced by federally insured credit unions as they use the reports and related systems, and any suggestions for improvement. NCUA intends to issue additional RFIs to solicit stakeholder input on other NCUA data collections and systems. Comments are due 06/23/2026 The notice may be viewed at: https://www.govinfo.gov/content/pkg/FR-2026-04-24/pdf/2026-08023.pdf Federal Register, Vol. 91, No. 79, 04/24/2026, 22172-22173.
NCUA Seeks Comment on Information Collection.
NCUA seeks comment regarding an information collection titled, Security Program, 12 CFR 748. Respondents are all federally insured credit unions, which are required by 12 CFR part 748 to develop a written security program to safeguard sensitive member information. Comments are due 07/06/2026. The notice may be viewed at: https://www. govinfo.gov/content/pkg/FR-2026-05-05/pdf/2026-08735.pdf Federal Register, Vol. 91, No. 86, 05/05/2026, 2429624297.
Compliance Notes
The Seventh Circuit U.S. Court of Appeals remanded the case involving the Illinois Interchange Fee Prohibitions Act back to the district court. The Act prohibits financial institutions, payment networks, and other entities from charging or receiving interchange fees in Illinois on the portion of a debit or credit card transaction related to tax or gratuity. The district court had upheld most of the law earlier this year. Since the district court entered its decision, OCC issued an interim final rule and order (included in the “Regulatory Spotlight” section of this publication) preempting the Act. The Seventh Circuit vacated the district court’s ruling and directed the court to address the matters and any related issues before the Seventh Circuit would attempt to do so. The order may be viewed at: https://business.cch.com/BFLD/IllinoisBankers-Association-v-Raoul-7thCir-Remand-ECF-97-05082026051126.pdf
FDIC released updated Q&As related to its regulation governing FDIC official signs, advertisement of membership, false advertising, misrepresentation of insured status, and misuse of the FDIC name or logo. The update reflects FDIC’s 2026 amendments to the rule (part 328). The Q&As provide answers to a collection of questions from stakeholders, including insured depository institutions, trade associations, technology companies, vendors, and other entities, and are intended to promote transparency and support implementation efforts. FDIC will continue to update the Q&As periodically on its website, as needed. The updated Q&As may be viewed at: https://www.fdic.gov/news/financialinstitution-letters/2026/updated-questions-and-answers-regarding-fdic-official-signs
FinCEN has re-issued frequently asked questions (FAQs) regarding CDD requirements for covered financial institutions. The FAQs were separately published 07/19/2016, 04/03/2018, and 08/03/2020, to assist covered financial institutions in understanding the scope of the final rule CDD rule, published 05/11/2016, and amended 09/27/2017 FinCEN re-issued the FAQs to consolidate the three sets of FAQs into one document and update certain FAQs to align with the Account Opening Exceptive Relief Order, issued 02/13/2026. The re-issued FAQs may be viewed at: https:// www.fincen.gov/resources/statutes-and-regulations/cdd-rule-faqs
FDIC released a report of its analysis for the Spring 2023 bank failures. The report includes key findings, an analysis of the types of deposits at each failed bank, a timeline of events, depositor run and other deposit outflow timelines, outflow rates of the largest deposit types, wire transfer requests, regression results, and conclusion. The report may be viewed at: https://www.fdic.gov/center-financial-research/staff-studies-may-2026.pdf
FinCEN issued 2026-Alert002 on the use of front companies, financial facilitators, and digital asset infrastructure by Iran’s Islamic Revolutionary Guard Corps (IRGC) to evade sanctions and launder proceeds. The alert supplements information related to FinCEN’s 2025 advisory on the Iranian Regime’s Illicit Oil Smuggling Activities, Shadow Banking Networks, and Weapons Procurement Efforts and its 2024 Advisory to Financial Institutions to Counter the Financing of Iran-Backed Terrorist Organizations. FinCEN requests that financial institutions reference the alert in SAR field 2 and the narrative by including the key term “FIN-2026-Alert002.” The alert may be viewed at: https://www.fincen.gov/system/ files/2026-05/FinCEN-Alert-IRGC.pdf
OCC reported the key issues facing the federal banking system in the Semiannual Risk Perspective for Spring 2026 OCC reported that bank earnings improved in 2025, supported by loan growth and a decline in funding costs. Balance sheets remain strong and credit risk within the federal banking system remains manageable. Earnings releases for the first quarter of 2026 indicate that these trends have generally persisted. The OCC highlighted credit, market, operational, and compliance risks, as key risk themes in the report. The report also discussed innovation. Highlights from the report include:
• Credit conditions and refinancing risk in certain segments of CRE lending and private credit markets warrant ongoing monitoring.
• Modest increases in past-due loans have been observed in some consumer portfolios. However, OCC-supervised banks have manageable exposures to borrowers with weaker credit profiles.
• Balance sheets remain strong, with capital ratios and liquidity high by historical standards.
• Cyber threats and fraud remain a concern. Cybercriminal groups targeting the financial sector are increasingly sophisticated, and foreign state-sponsored actors continue to pose a threat. Banks continue to face challenges from both the elevated levels and rising sophistication of fraud and scams.
• A sound understanding of the potential benefits and possible risks associated with increasingly advanced AI tools coming onto the market that can assist with cybersecurity functions can be important for cyber risk management.
• Geopolitical tensions increase sanctions and money laundering risk, straining bank compliance systems, and may raise the potential for sanctions and BSA/AML violations.
Compliance Notes
The report may be viewed at: https://www.occ.gov/news-issuances/news-releases/2026/nr-occ-2026-35.html
HUD announced updates to environmental review requirements for multifamily housing, removing outdated provisions that have increased costs and complexity for lenders and developers. The changes, issued through HUD’s Federal Housing Administration (FHA) via a mortgagee letter revise the Multifamily Accelerated Processing (MAP) Guide to streamline outdated and burdensome requirements for lenders and developers seeking FHA-insured financing. The announcement and mortgagee letter may be viewed from the following links, respectively, https://www.hud.gov/ news/hud-no-26-032 and https://www.hud.gov/sites/default/files/hudclips/documents/2026-04hsgml.pdf
The Federal Reserve Financial Services’ FedCash® Services released the results of its annual survey measuring the evolving role of cash in the U.S. economy. The national survey revealed that U.S. consumers’ payment use remained largely consistent over the past three years, even amid technological changes and other activity in the payments ecosystem. The report may be viewed at: https://www.frbservices.org/news/research/2026-findings-diary-consumerpayment-choice
The agencies issued updated host state loan-to-deposit ratios, as required by law. Each ratio compares the total loans in a state to total deposits in the state for all banks that are legally operating in that state. The ratios replace those issued in May 2025. By law, a bank is generally prohibited from establishing or acquiring branches outside of its home state primarily for the purpose of acquiring additional deposits. The prohibition seeks to ensure that interstate bank branches will not take deposits from a community without the bank also reasonably helping to meet the credit needs of that community. The ratios may be viewed at: https://www.occ.gov/news-issuances/news-releases/2026/nr-ia-2026-33. html
SBA announced that it has referred 562,000 suspected fraudulent loans to the Treasury for collection. The borrowers are tied to $22.2 billion in delinquent Paycheck Protection Program (PPP) and COVID Economic Injury Disaster (EIDL) loans that were previously flagged for suspected fraud during the previous administration but never sent to Treasury for collection nor referred to the DOJ for investigation. With the referral, Treasury will begin collecting on the outstanding debt. The announcement may be viewed at: https://www.sba.gov/article/2026/04/24/sba-sends-562000suspected-fraudulent-loans-treasury-collections-totaling-22-billion
HUD and FHFA announced that FHA, Fannie Mae, and Freddie Mac are implementing their first new credit score models for mortgages in decades. FHA will permit the use of VantageScore 4.0 and FICO 10T as eligible credit scoring models for FHA-insured mortgage underwriting. Fannie Mae and Freddie Mac have also moved forward with VantageScore 4.0 and FICO Score 10T, updating their selling guides with the new scores and immediately accepting Vantage-scored loans from approved lenders. The announcement may be viewed at: https://www.fhfa.gov/news/newsrelease/homebuying-advances-into-new-era-of-credit-score-competition
The Social Security Administration has released a new resource, “Enhancing Financial Wellness: Promoting Online my Social Security Account Awareness” to help financial institutions inform their customers about online “my Social Security” accounts. The resource may be viewed at: https://www.ssa.gov/thirdparty/assets/materials/enhancingfinancial-wellness.pdf
SBA announced it will allow eligible borrowers to combine their 7(a) and 504 loans for up to $10 million in SBAbacked financing, increasing the cumulative loan limit from its current $5 million and expanding the capital available to small businesses across all industries. Small manufacturers, who can currently secure an unlimited number of 504 loans as long as each loan is tied to a distinct project, will also be able to apply for $5 million through the 7(a) loan program. Effective July 4, the rule will raise SBA’s maximum financing offering to small businesses to the highest level in agency history. The announcement may be viewed at: https://www.sba.gov/article/2026/05/18/sba-doubles-cumulative-7a-504loan-limit-10-million
June 3 Fraud Summit Wisconsin Dells – $275/attendee 10 Online Workshop: Advanced Cash Flow Analysis
11-12
Virtual full day – $275/attendee
BOLT Summer Leadership Summit
Wisconsin Dells – $300/attendee
16 Compliance Forum: Session I
Stevens Point – $1,500/bank, 2 primary members
17 Branch Manager Boot Camp: Session II
22-23
Four-part series, virtual half days – $900/attendee
2026 Benefit for WBA Advocacy: Kohler Outing
Kohler
24 Online Workshop: Wowing the Client!
Virtual half-day – $300/attendee
ongoing Fraud On-Demand Video Series
Five-part video series – $995/bank
July
15 Branch Manager Boot Camp: Session III
Four-part series, virtual half days – $900/attendee
21 Community Bankers for Compliance –Session III
Virtual half-day – annual membership/pricing varies
28 Workshop: Numbers Talk, Bankers Need to
Listen
Madison - $275/attendee
TBD Hot Topics in Commercial & Agricultural
Lending Webinar Series
Multi-part webinar series
August
Madison, three-day school with optional 8/3 pre-school
- $895/attendee; $250/workshop addition
Branch Manager Boot Camp: Session IV
Four-part series, virtual half days – $900/attendee
September
Principles of Banking
1-2 9-10 22-23
Grafton - $550/attendee
Fond du Lac - $550/attendee
Madison - $550/attendee
September continued
9 Strategic Management Summit
Stevens Point – $275/attendee
15-16 Consumer Lending Boot Camp
16
Madison – $550/attendee
Milford Hills Outing
Johnson Creek
24 Wisconsin Bankers Foundation Gala
Madison
28 Innovation Showcase
Wisconsin Dells – multiple registration options
29-30 Bank Technology & Security Summit
Wisconsin Dells – multiple registration options
TBD Personal Banker School
Fall dates/locations TBD - $550/attendee
TBD BSA/AML Workshop
Location TBD - $275/attendee
October
7-8 Supervisor Boot Camp
Madison – $550/attendee
13-14 Advanced Commercial Lending Boot Camp
Madison – $550/attendee
14 Online Workshop: C&I Lending in Today’s Competitive Environment
Virtual full day – $275/attendee
15 FDIC Bank Directors Summit
Madison - $275/attendee
20 Community Bankers for Compliance – Session IV
Virtual half-day – annual membership/pricing varies
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 area of banking.
WBA-Hosted Webinars
Other Events
www.wisbank.com | 608-441-1252 | wbaeducation@wisbank.com