Wetland banking has been discussed in the policy literature mainly at a high level of abstraction, using economic models or generic examples to illustrate the concepts and tensions within wetland banking. This article illustrates two cases of wetland bank creation in-depth using the methodology of the extended case study, following the process from the initiation of interest in forming a bank through to the approval of credits for sale. The close attention to actual cases serves to move discussion beyond the goodness of models or the supposed rationality of economic actors, towards a consideration of actual market participants in complex situations. Successful wetland credit producers must negotiate a number of different economic, political, interpersonal, and ecological forces which impact their project from a number of different scales. While no optimal solution to this complexity is likely to be reached that is generalizable, the use of entrepreneurial wetland banking as a market-based policy may expand where skillful bankers and regulators together arrive at adequate solutions that are matched to the specificity of their contexts.