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Western District of Wisconsin Ranks 2nd in the Nation in Chapter 12 Farm Bankruptcy Filings in 2018

Posted on January 29, 2019 by

The latest federal bankruptcy statistics contain more bad news for Wisconsin’s farmers. Chapter 12 farm bankruptcies continue to rise even though overall bankruptcies continue to fall. Although total bankruptcy filings (including Chapter 7, Chapter 11, Chapter 12 and Chapter 13) in the Western District of Wisconsin fell 2.8% in 2018 and have decreased every year […]

Expanded Examination Cycle

Posted on November 5, 2018 by

The OCC, the Board of Governors of the Federal Reserve System, and the FDIC published an interagency interim final rule effective August 29, 2018.  The interim final rule amends the regulations governing eligibility for an 18-month on-site examination cycle.  Under the interim final rule, qualifying depository institutions with less than $3 billion in total assets […]

Is Your Website Accessible to Individuals with Disabilities?

Posted on July 30, 2018 by

Many are unaware that the Americans with Disabilities Act (“ADA”) applies to websites as well as physical facilities. A review of court dockets around the country shows that plaintiffs are filing an increasing number of lawsuits against companies alleging that their websites are not “accessible” to individuals with disabilities as required by the ADA. In […]

Interagency Guidance on Accounting and Reporting Implications of Tax Cuts & Jobs Act

Posted on February 16, 2018 by

On January 18, 2018, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency released guidance on the accounting implications of the Tax Cuts & Jobs Act (the “Act”) signed into law on December 22, 2017.  The guidance provides information on the […]

Ruder Ware Attorney Provides Comments on Ag Lending Market

Posted on January 26, 2018 by

Chris Seelen, a member of Ruder Ware’s Banking and Financial Institutions Focus Team, recently provided comments on Wisconsin’s ag lending market for Wisconsin Public Radio.  The WPR story focused on new federal court data that shows the Western District of Wisconsin had the highest number of farm bankruptcies in the country last year.  

Western District of Wisconsin Ranks 1st in the Nation in Chapter 12 Farm Bankruptcy Filings in 2017.

Posted on January 24, 2018 by

Low grain and milk prices have negatively affected Wisconsin’s ag economy for a few years now.  As further evidence of the financial stress on Wisconsin farmers, the national bankruptcy statistics show that, in 2017, more Chapter 12 farm bankruptcy cases were filed in the Western District of Wisconsin than in any other district in the […]

Conference of State Bank Supervisors Urges Federal Regulators to Simplify Regulatory Capital Rules

Posted on January 5, 2018 by

On September 27, 2017, the FDIC, the Federal Reserve, and the OCC (the “Agencies”) issued a proposed rule that simplifies the compliance requirements of the existing regulatory capital rules and is intended to reduce the regulatory burden imposed by it. Developed with small- and medium-sized banks in mind, the proposed rule would: replace the complex […]

Examiners are Carefully Scrutinizing Financial Institutions’ Compensation Arrangements

Posted on December 13, 2017 by

It has come to our attention that some examiners have recently been carefully scrutinizing financial institutions’ employee compensation arrangements. Although it now appears unlikely that the proposed Dodd-Frank rules on financial-institution incentive compensation (which only apply to institutions with at least $1 billion in total assets) will ever take effect, examiners still do take compensation, […]

OCC Updates Guidance on Business Combinations

Posted on December 1, 2017 by

The Office of the Comptroller of the Currency (“OCC”) has recently updated its “Business Combinations” booklet, which is part of the Comptroller’s Licensing Manual.  The revised booklet replaces the prior version, which was issued by the OCC in December 2006.   The booklet incorporates a variety of updated procedures and requirements for national banks and federal […]

To Arbitrate or Not Arbitrate? House Weighs In on CFPB Arbitration Rule

Posted on August 2, 2017 by

Yesterday, the U.S. House of Representatives overwhelmingly passed House Joint Resolution 111 which would rescind the Consumer Financial Protection Bureau’s “Arbitration Rule”. Finalized on July 17, 2017, the Arbitration Rule places significant limitations on financial institutions’ ability to designate arbitration as the dispute resolution mechanism in its contracts with depositors and borrowers; additionally, the Rule […]