SEC Division of Corporation Finance no-action letter: Mid-Wisconsin Financial Services, Inc.

BARACK FERRAZZANO KIRSCHBAUM & NAGELBERG LLP
200 WEST MADISON STREET, SUITE 3900
CHICAGO, ILLINOIS 60606
Brad A. Kopetsky
(312) 629-7312 Telephone (312) 984-3100
Voice Mail Ext. 7312 Facsimile (312) 984-3150 brad.kopetsky@bfkn.com
Section 15(d) of the Securities Exchange Act of 1934
Rule 12h-3 under the Securities Exchange Act of 1934 VIA ONLINE SUBMISSION (https://www.sec.gov/forms/corp_fin_noaction) Office of the Chief Counsel 100 F. Street N.E. Washington, DC 20549 Re: Mid-Wisconsin Financial Services, Inc. (Commission File No. 000-18542) Ladies and Gentlemen:
On behalf of Mid-Wisconsin Financial Services, Inc., a Wisconsin corporation (the “Company”), we hereby request that the Staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) confirm that it concurs with the Company’s view that it should not be precluded from using Rule 12h-3 (“Rule 12h-3”) under the Securities Exchange Act of 1934, as amended (the “Exchange Act”), to suspend its duty to file with the Commission the reports required by Section 15(d) of the Exchange Act (“Section 15(d)”) and the rules and regulations promulgated thereunder, that will revive once the Company’s reporting obligation under Section 12(g) of the Exchange Act has been terminated. On September 21, 2012, the Company filed a Form 15 with the Commission to deregister its common stock, $0.10 par value per share (the “Common Stock”), under
Section 12(g)(4) of the Exchange Act. Pursuant to Section 12(g)(4) of the Exchange Act, the
Section 12(g) registration will be terminated in 90 days (December 20, 2012), or such shorter period
as determined by the Commission. Subject to the Staff’s concurrence with the requests set forth in this letter, the Company intends to file a Form 15 pursuant to Rule 12h-3(b)(1)(i) to suspend its reporting obligations under Section 15(d) following the end of this 90-day period and prior to the April 1, 2013 filing deadline for its Form 10-K for the year ended December 31, 2012.1
I. Background:
Organized as a Wisconsin corporation in 1986, the Company is currently a non-accelerated filer, specifically qualifying as a smaller reporting company (as defined by Rule 12b-2 under the Exchange Act). The Company is registered as a bank holding company (as defined in Section 2 of the Bank Holding Company Act of 1956 (12 U.S.C. 1841)) for its wholly-owned banking subsidiary, Mid-Wisconsin Bank. The Company registered its Common Stock under Section 12(g) of the