OVER A CENTURY: BUILDING BETTER BANKS — Helping Coloradans Realize Dreams November/December CHAIRMAN’S MESSAGE BRETT WYSS, 2025-2026 CHAIRMAN SAFEGUARDING TRUST The Role of the Deposit Insurance Fund
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©2025 The Colorado Bankers Association (CBA) | The newsLINK Group LLC. All rights reserved. Colorado Banker is published six times per year by The newsLINK Group LLC for CBA and is the official publication for this association. The information contained in this publication is intended to provide general information for review, consideration and education. The contents do not constitute legal advice and should not be relied on as such. If you need legal advice or assistance, it is strongly recommended that you contact an attorney as to your circumstances. The statements and opinions expressed in this publication are those of the individual authors and do not necessarily represent the views of CBA, its board of directors or the publisher. Likewise, the appearance of advertisements within this publication does not constitute an endorsement or recommendation of any product or service advertised. Colorado Banker is a collective work, and as such, some articles are submitted by authors who are independent of CBA. While a first-print policy is encouraged, in cases where this is not possible, every effort has been made to comply with any known reprint guidelines or restrictions. Content may not be reproduced or reprinted without prior written permission. For further information, please contact the publisher at (855) 747-4003. Jenifer Waller President & CEO Alison Morgan Director of State Government Relations Brandon Knudtson CFO & Director of Membership Lindsay Muniz Director of Education Parker Terrell Communications Specialist Megan Carruth Executive Assistant Margie Mellenbruch Bookkeeper* Melanie Layton Lobbyist* Garin Vorthmann Lobbyist* Caroline Woodhouse Lobbyist* *Outsourced 140 E. 19th Ave., Ste. 400 Denver, Colorado 80203 Office: (303) 825-1575 coloradobankers.org colorado-banker.thenewslinkgroup.org BUILDING BETTER BANKS — Helping Coloradans Realize Dreams 8 16 2025-2026 Issue 3 4 CHAIRMAN’S MESSAGE Safeguarding Trust The Role of the Deposit Insurance Fund By Brett Wyss, Chairman, CBA 6 From Hype to Headache? The HR and Legal State of Unlimited PTO By Chelsea Jensen, SHRM-CP, PHR, and Edward Encinias, Esq. 8 Navigating Regulatory Uncertainty With a Compliance Management System By Troy Snyder, Brad Birkholz and Ryan Colleran, Plante Moran 12 CBA Centerpoint Going Beyond the Desk to Hear the Stories of Colorado Bankers 14 How Deposit Flows Are Reshaping the U.S. Banking Landscape By Tim Groth, Vice President, Data Analytics, IntraFi 16 Insurance Tracking for Multi‑Collateralized Loans By MeKelee LaFoy, CP Insurance Associates 18 From SEO to GEO Why Banks Must Lead in the Age of AI Search By Joe McMann, Co‑Founder & CRO, Artificial Intelligence Risk Inc. 20 Building Consensus Around Tech Adoption in Banking By Neal Reynolds, President, BankMarketingCenter.com 22 Fraud’s New Frontier Can Regulators Keep Up with the Fraud Frenzy? By Carol Ann Warren, Associate General Counsel, Compliance Alliance 3 Colorado Banker
CHAIRMAN’S MESSAGE Safeguarding TRUST THE ROLE OF THE DEPOSIT INSURANCE FUND There are several legislative proposals regarding deposit insurance reform. Congresswoman Waters (D-CA) reintroduced H.R. 4551, the “Employee Paycheck and Small Business Protection Act.” This bill would update the deposit insurance framework for business payment accounts to ensure small businesses can bank with community financial institutions and continue to pay their employees, even if their bank or credit union unexpectedly fails. This bill also enhances emergency tools for the FDIC and National Credit Union Administration (NCUA) to use in future crises. Senator Hagerty (R-TN) filed an amendment that would insure up to $20 million per depositor in the aggregate across noninterest-bearing business accounts. He wanted the amendment to be included in the National Defense Authorization Act, but the amendment was not included. This concept was discussed in the Senate Committee on Banking, Housing and Urban Affairs on Sept. 10. We expect a bill to be introduced that includes increased coverage for non-interest-bearing business accounts. CBA is committed to advocating for policies that protect the integrity of DIF and increase consumer confidence without placing undue burdens on banks. Strong banks mean a strong DIF, and a strong DIF means a resilient financial system. Our job as leaders is to ensure that this cycle isn’t broken by short-term thinking or reactive policymaking. That means advocating not just for today’s solvency, but for sustainability. By Brett Wyss, Chairman, CBA Having spent my career in banking, I’ve seen how trust is the foundation of everything we do. That includes banks and customers, regulators and institutions and within our communities. Nothing underscores that trust more than the Deposit Insurance Fund (DIF). I’ve been reflecting on how we, as an industry, can help ensure that public confidence in the banking system remains strong and unwavering. That brings me to a key focus area I’d like to highlight for the year ahead: supporting the strength, sustainability and transparency of the DIF. The DIF needs reform. Key changes we are seeking include: • A base increase from the existing $250,000 coverage. • Indexing the increase so the coverage increases automatically with inflation increases. Having to ask Congress for an increase every 10+ years is not efficient. • An increase in coverage on non-interest-bearing business accounts, providing protection for payroll accounts. • Authority of the Treasury to invoke a temporary assets guarantee (TAG) for 120 days. This will be much faster than Congress having to approve TAG. TAG calms depositors by ensuring all deposits are protected. The 120-day period gives markets time to adjust and stabilize. • Having the FDIC explore offering additional insurance to banks that wish to purchase it. This may or may not be appropriate for the FDIC, but it should be explored. • Having the FDIC study what the costs will be for the industry. Senate Banking Committee Chairman Scott (R-SC) asked the FDIC to provide additional information about the amount of uninsured deposits in the U.S. banking system and the cost to banks should the deposit insurance limit be increased. Colorado Banker 4
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The concept of unlimited paid time off (UPTO) has been a topic of discussion in workplace conversations since the early 2000s. What began as a bold alternative to rigid vacation policies — initially championed by startups and tech firms — quickly became a symbol of modern workplace culture. Over the years, it has gained traction, sparked debates and prompted a steady stream of HR think pieces, all attempting to determine whether the promise of autonomy materializes in practice. While some organizations have adopted it to attract talent and simplify administration, others have questioned whether it is genuinely beneficial or just good optics. UPTO policies sound generous and progressive, offering employees the freedom to take time off as needed, without a formal cap. In practice, a truly unlimited PTO plan removes accruals altogether. There is no balance to track, no carryover into the new year and typically, no payout at separation. Employees are trusted to take time off as needed, provided business needs are met. These policies often merge all leave types (vacation, sick, personal) into a single, flexible benefit. And while “unlimited” sounds absolute, most employers still impose boundaries around extended leaves and require manager approval. So, while “unlimited” PTO may be untracked, it is not without rules, and employees are usually very aware of the boundaries. A Look Back: Growth, Hype and Now a Plateau The early 2010s marked a sharp rise in organizations experimenting with UPTO, particularly in high-growth industries like tech and finance. According to Employers Council’s 2018 survey, there was a 25% increase in organizations offering UPTO between 2016 and 2018. Fast forward to 2024, and the trend appears to be cooling. Only 7% of U.S. employers currently offer UPTO, down from 8.8% of job postings in 2022. Some organizations are reversing course, moving back to structured and limited policies in response to employee confusion, administrative headaches, compliance concerns and evolving state leave laws. Do Employees Take More Time Off? A central fear among employers offering UPTO has always been overuse. The data tells a different story. • Cloud-Based HR Platform Namely’s 2017 HR Mythbusters Report: Employees with UPTO took an average of 13 days off, compared to 15 days for employees with capped vacation. • Empower Financial Services’ 2024 Research: UPTO employees took 16 days off, only slightly more than the 14-day average in traditional plans. Cultural factors — such as fear of judgment or concerns about workload — seem to outweigh policy generosity. Many employees underuse the benefit, often feeling guilty for taking time off or unsure about what is “acceptable.” Nearly 70% of employees admitted to working during vacation, and half check email regularly while away. Despite its shortcomings, UPTO remains a top-ranked benefit. Empower reports that: • 43% of employees believe every organization should offer UPTO. • 26% would consider a lower-paying job if it came with UPTO. • 19% would not accept a new job unless this benefit was offered. Employees are drawn to the perception of autonomy, flexibility and trust, even if the policy itself does not result in employees taking significantly more time off. Legal and Compliance Hurdles: The Catch What seemed like a simple swap — ditch accruals and hand employees the keys to their calendars — has proven to be anything but simple. The legal landscape has become increasingly complex, and employers must exercise caution. 1. State and Local Sick Leave Laws States like Colorado, California and New Mexico require employers to provide a defined number of paid sick leave hours, with specific conditions for documentation. These From Hype to Headache? THE HR AND LEGAL STATE OF UNLIMITED PTO By Chelsea Jensen, SHRM-CP, PHR, and Edward Encinias, Esq. Colorado Banker 6
state sick leave laws also provide protection against retaliation. Broad UPTO policies often lack the structure to ensure compliance, particularly when tracking the reason for time off is avoided or discouraged. Broad UPTO policies may suggest to employees that all time off is protected by state sick leave laws. 2. FMLA and ADA Considerations Unlimited PTO policies may unintentionally convert unpaid FMLA or ADA-protected leave into paid leave, exposing employers to legal risk if not applied consistently. To reduce liability, employers should clearly separate unlimited vacation from medical leave and maintain distinct policies for FMLA, ADA and state sick leave compliance. 3. Wage and Hour Risks Though courts have not definitively ruled on whether an “unlimited” model fully protects against claims for unpaid leave upon separation, states like Colorado treat accrued vacation as earned wages. Employers converting to UPTO need a clear plan to handle existing balances. Since the Colorado Wage Act prohibits employers from employing a “use it or lose it” type policy, employers should encourage the use of earned PTO prior to converting to an UPTO policy. 4. Manager Discretion and Fairness Managerial inconsistency is a recurring challenge. Without clear criteria for approvals, employees may perceive favoritism or experience fundamental inequities, which can lead to morale issues or potential legal claims. 5. State Paid Leave Considerations Colorado, like many other states, offers partially paid family and medical leave to employees. Colorado’s Family and Medical Leave Insurance (FAMLI) program offers 12 weeks of partially paid leave to eligible employees. Employees might utilize their unlimited paid time off in lieu of applying for FAMLI benefits, prolonging an employee’s ability to later use job-protected leaves like FAMLI. Should Employers Offer It? Benefits: • Strong appeal among younger talent. • Reduced administrative tracking. • Potential savings from not paying out unused leave. Risks: • Legal compliance with sick leave, FMLA and wage laws. • Inconsistent usage and underuse by employees. • Managerial confusion and inconsistent enforcement. • Potential resentment from employees who are not eligible for the benefit. Edward Encinias, Esq., and Chelsea Jensen, SHRM-CP, PHR If you are considering rolling out or refining an unlimited PTO policy, take the following steps: 1. Define Who Gets It: Will it apply to all staff? Only exempt employees? Be clear and transparent. 2. Handle Accrued Leave Carefully: Consult legal counsel about paying out or phasing out existing PTO balances. 3. Coordinate with Other Leave Policies: Ensure that FMLA, ADA, HFWA (Colorado only), FAMLI (Colorado only) and other leaves are clearly defined and not overly broad in your UPTO model. 4. Train Managers: Equip them with guidance and documentation tools to ensure consistent approvals. 5. Clarify the Policy to Staff: Communicate expectations, coordination with other leaves and the process for administering the benefit. 6. Consider Hybrid Models: Some employers are adopting generous yet structured policies that strike a balance between clarity and flexibility. Unlimited PTO originated as an innovative initiative aimed at fostering autonomy and trust. Two decades in, the model has matured — and shown its limits. While some organizations still find it valuable, others are scaling back, citing confusion, legal complexity and cultural clashes. It remains an option — but not a cure-all. As of now, UPTO is less a revolution than a choice. For some organizations, it works. For others, it may be time to return to clearly defined, equitable and manageable leave programs. Either way, the key is thoughtful design, legal awareness and a culture that encourages people to take the time they need. If you have questions or need support tailoring a compliant approach for your organization, contact the Employers Council for guidance. Also, members can reference the UPTO white paper on our website by scanning the QR code. https://members.employerscouncil.org/viewdocument/ unlimited-paid-time-off-plans 7 Colorado Banker
The regulatory environment for financial institutions is complex and constantly changing. Bankers should learn how a robust compliance program, coupled with a compliance management system, ticks all the boxes to maintain integrity and adaptability in the face of uncertainty. Rapid changes in the regulatory landscape have created new and unexpected compliance challenges for financial institutions. The issue isn’t missing deadlines or failing to comply — boards and executives are grappling with the complexities of tracking compliance obligations amid ongoing regulatory shifts and adapting their programs in a timely manner. Many of these challenges stem from recent changes in regulatory agencies, including the Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation, the NCUA and the Office of the Comptroller of the Currency. A stated theme in these developments has been to reduce bureaucracy and streamline; however, the ensuing restructuring, leadership changes, rescinding of prior guidance and changes in the emphases of regulatory reviews have complicated the compliance journey for financial institutions, leaving many in a state of ambiguity, struggling to decipher compliance obligations and anticipate future requirements. Further complicating matters are legal challenges to major regulations. For example, Section 1071 of the Dodd-Frank Act, which requires financial institutions to collect and report demographic data on small business loan applications, is currently in a state of legal limbo. Although the CFPB finalized its implementing rule in 2023, ongoing lawsuits have resulted in court-ordered delays and ongoing uncertainty regarding enforcement. Similarly, efforts to modernize the Community Reinvestment Act have faced setbacks, with rule changes being rescinded and new proposals under consideration. With institutions caught in a “wait-and-watch” regulatory environment, one thing can be said for certain: Complacency isn’t an option. Now more than ever, engaged leadership is critical to ensure that compliance is a strategic priority as new rules emerge and old ones are rescinded. In this climate of uncertainty, organizations need more than reactive measures — they need a proactive, structured approach to compliance. This is where an effective Compliance Management System (CMS) becomes essential. Compliance Management System Fundamentals A CMS is a critical framework that institutions use to ensure they operate within legal and regulatory boundaries while upholding internal policies and ethical standards. It provides a structured approach to identifying, managing, monitoring and mitigating compliance risks across all levels of the organization. A well-designed CMS not only helps prevent violations but also fosters a culture of accountability and integrity. At the heart of an effective CMS are two foundational cornerstones: board and management oversight and a robust compliance program. These elements work in tandem to establish clear expectations, allocate responsibilities and ensure ongoing adherence to applicable laws and regulations. Effective board and management oversight begins with setting a strong tone at the top. Visible commitment to compliance sends a clear message throughout the organization that regulatory responsibility is a shared priority. In today’s unpredictable regulatory environment, this leadership is essential for accountability and agility. When boards and executives are actively engaged, they can help institutions respond quickly to change, allocate resources effectively and ensure that compliance remains integrated into strategic decision-making. A successful compliance program in a rapidly changing environment operationalizes an institution’s commitment to regulatory integrity and translates the oversight into action through policies, procedures, oversight, training, monitoring and reporting back to the board. It involves a combination of Navigating Regulatory Uncertainty With a Compliance Management System By Troy Snyder, Brad Birkholz and Ryan Colleran, Plante Moran Colorado Banker 8
tools, business processes and internal controls designed to ensure orderly regulatory compliance and reduce risk, and it enables institutions to adapt quickly, identify emerging risks and maintain consistent standards across business lines. It ensures that compliance is not a one-time effort, but a continuous process that evolves with the environment. To deal with evolving regulations effectively, your CMS should have capabilities in the following core areas. Board and Management Oversight Board of Directors • Strategic Oversight and Accountability: As the ultimate authority over your institution’s CMS, the board is responsible for setting a strong tone at the top — demonstrating a clear and consistent commitment to compliance and ethical conduct. This leadership includes defining your institution’s compliance risk appetite, ensuring it aligns with business objectives, and approving key policies such as your compliance framework, risk assessments and governance structure. Your board should formally appoint a qualified compliance officer and ensure that the compliance function is properly resourced, empowered and independent. By regularly reviewing compliance reports and acting on findings, your board helps drive accountability and responsiveness. It also plays a vital role in overseeing third-party risk, ensuring that vendor and partner relationships are governed by appropriate compliance expectations and controls. In times of regulatory uncertainty, this level of strategic oversight helps your institution remain agile, informed and prepared. Senior Management • Operational Execution and Implementation: Your senior management team is responsible for turning your board’s compliance vision into reality by embedding it into day-to-day operations. This includes implementing your compliance program by translating board-approved policies into actionable procedures and controls across business units. Your leaders must supervise compliance staff, ensuring they have the authority and independence needed to monitor and enforce standards effectively. Senior management also plays a key role in conducting compliance risk assessments, identifying and evaluating risks across the institution, and reporting findings back to your board. Through ongoing monitoring, testing and issue tracking, they help ensure timely resolution of compliance concerns. Just as importantly, they promote a culture of compliance through regular training and clear communication, helping your entire organization stay informed, engaged and agile in the face of regulatory change. Compliance Program • Policies and Procedures: Given the current volatile landscape, policies must be readily adaptable. Your CMS should include clear documentation aligned with current laws and regulations, along with capabilities to quickly facilitate updates reflecting new or rescinded regulations. With institutions caught in a “wait-and-watch” regulatory environment, one thing can be said for certain: Complacency isn’t an option. 9 Colorado Banker
This function should include a policy review calendar that aligns with regulatory developments, coupled with a version control system to ensure that your staff operates from the latest guidelines. Implementing a rapid response protocol for immediate updates will prevent falling behind during legal shifts. • Monitoring and Testing: Regular evaluations of business activities are crucial for maintaining compliance and identifying weaknesses. Your CMS should prioritize high-risk areas for more frequent testing and employ data analytics to detect potential compliance drifts. By leveraging real-time dashboards for risk visibility, it’s possible to eliminate repeat findings and improve governance. Thorough documentation of your findings and remediation efforts underscores a proactive risk management approach. • Compliance Audit: Your CMS should facilitate independent reviews to validate the effectiveness of controls and identify areas for improvement. Audits provide a reality check on how well your institution can adapt to regulatory changes, ensuring interim policies and procedures are compliant and effective. • Issue Management and Corrective Action: It’s critical to track, resolve and prevent recurring issues. By incorporating these processes into your CMS, you demonstrate proactive compliance to regulators and highlight your institution’s capacity to tackle issues amid shifting regulations. • Consumer Complaint Response: Complaints are often more than just isolated issues; they’re an early warning system for compliance risks tied to unclear or changing rules. By leveraging them effectively, you can identify patterns of potential consumer harm that can draw regulatory focus. By integrating complaint management within your CMS, analyzing trends and updating training, you can reduce complaints, improve customer satisfaction and minimize compliance risks. To facilitate this, your CMS should include centralized complaint intake, analysis of trends and integration with risk functions. Training staff on effective complaint handling will help bridge gaps, fostering a proactive culture of compliance and risk awareness. • Training: If a regulator knocked on your door today, could you prove that your teams are up to date with the current rules? Your CMS ensures accurate delivery and tracking of ongoing and role-specific training for all staff, including core compliance knowledge and recent changes. It can deliver “compliance alert” training as rules change, tailor content for role relevance, and track completion to ensure accountability. This approach underlines a culture of compliance, which is vital when external guidance fluctuates. Taking the Next Step With concerns over personal liability and reputational fallout from compliance breaches, many financial institution leaders are experiencing the mental toll of “what if we miss something?” Now’s the time to answer that question by assessing your current CMS. Is it equipped for today’s pace of regulatory change? Are your compliance processes both integrated and auditable? Do you have the visibility and controls needed to stay ahead of the risks? Is your CMS agile enough to adapt to new rules quickly? If any of these questions raise concerns, consider bringing in experienced advisors for a CMS assessment. They can review your compliance program, help identify potential gaps and explore solutions that will ensure both day-to-day and long-term regulatory success. Compliance today is more than just meeting deadlines — it’s about confidently navigating the complexities of tomorrow. A strong CMS is a vital tool in keeping your financial institution ahead of evolving expectations. Read more insights from our trusted advisors at Plante Moran by scanning the QR code. https://www.plantemoran.com/exploreour-thinking?utm_source=cba2025&utm_ medium=email&utm_campaign=PEN-FSG-2025_CBA Colorado Banker 10
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CBA Centerpoint GOING BEYOND THE DESK TO HEAR THE STORIES OF COLORADO BANKERS Karissa Becklund Chief Credit Officer High Plains Bank How did you get started in the banking industry? While in college in North Dakota, I started as a teller. During that time, I also went through a summer internship at the bank that truly set my career path. I spent time in five different departments, ultimately discovering my passion for loans, which has been a consistent focus throughout my banking career. What makes your bank unique? High Plains Bank’s core philosophy is family first, then community, then the bank. High Plains Bank is family and employee-owned which helps maintain its independent, community-focused mission and is a Certified Evergreen business, which is a designation for privately held companies that are committed to remaining independent for the long term. High Plains Bank refers to its approach as “craft banking,” which means it’s committed to understanding the specific needs of each customer to tailor financial solutions with personalized, high-touch service that goes beyond standard transactions. What is the most rewarding aspect of your job? The most rewarding part of my job is seeing how our work directly impacts the community. By making sound credit decisions, we help local businesses grow, entrepreneurs launch new ventures and provide capital to rural areas of Colorado. It’s incredibly fulfilling to know that our bank is a vital part of the economic engine that keeps Colorado thriving, and I’m proud to play a role in fostering that growth. When you were a child, what did you want to be when you grew up? As a kid, I wanted to be a veterinarian. While I love animals, I now get way too queasy to handle anything in the medical profession! What do you listen to on your morning commute? Nothing gets me ready for the day quite like some good country music. I start things off by listening to a local country radio morning show! Max Meints Centralized Operations FirstBank How did you get started in the banking industry? I got into banking because I wanted to use my economics degree from the University of Colorado in a space where I could be creative, make an impact and lead with a people-first approach. I found that at FirstBank. I work in Centralized Operations, which means I’m behind the scenes, not interacting with customers directly, but supporting our internal teams. I really see our employees as my customers. Helping them do their jobs better is how I contribute to the bigger picture. What is the most rewarding aspect of your job? One of the things I enjoy most about my job is seeing a project through from start to finish. Taking an idea and turning it into something real that improves how we work is always a good feeling. Just as rewarding is seeing my team grow. I love being part of their development and watching them become stronger both in their roles and as people. I’m also very involved in our employee engagement efforts. I care a lot about creating a work environment where people feel connected, supported and appreciated. Whether it’s organizing team-building events, celebrating wins or encouraging collaboration, I believe that when employees feel good about where they work, it shows in everything they do. When you were a child, what did you want to be when you grew up? As a kid, I dreamed of being a professional athlete. While that dream changed course, the values I admired in sports like discipline and teamwork have followed me into my career. Tell us something about yourself most people don’t know. Something most people don’t know about me is that before working at the bank, I spent three years on cruise ships as part of the daycare staff. I had the opportunity to visit more than 30 countries during that time. The experience taught me a lot about myself, the importance of adaptability and the value of hard work, especially in high-pressure and fast-paced environments, such as banking. Colorado Banker 12
Esgar Acosta Senior Vice President and Head of Community Inclusion & Engagement Alpine Bank How did you get started in the banking industry? My journey with Alpine Bank began in 1996 when I was one of the first recipients of the Alpine Bank Hispanic Scholarship. That opportunity helped me attend Colorado Mountain College (CMC), earn an associate degree and become a certified police officer in Colorado. Since then, my career has spanned law enforcement, education and community leadership. Before entering banking, I worked at Carquest Auto Parts while applying to various law enforcement positions. I was invited by Rachel Gerlach — then president of Alpine Bank’s Eagle branch and a high school classmate — to consider a career in banking. At first, I said no, I couldn’t imagine being behind a teller line all day. But when she explained she was looking for a lender and that I’d be trained, I decided to give it a try. I joined Alpine Bank in 2006 and haven’t looked back. What is the most important thing you’ve learned from a career in banking? Over the years, I’ve served on more than 15 nonprofit boards and now lead efforts to strengthen equity and outreach across Colorado. One of the most important lessons I’ve learned in banking is that, at the end of the day, it’s just people doing business with people — a message our leadership at Alpine Bank continues to reinforce. Tell us about your family. I live in Gypsum, Colorado, with my wife, Karla, a first-grade teacher working on her master’s degree, and our two children, Luna and Gael. Luna is taking college courses through CMC while still in high school, and Gael is active in sports and school organizations. What topic could you give a 20-minute presentation on without any preparation? If you asked me to speak for 20 minutes without preparation, I’d talk about Alpine Bank or financial literacy — topics I’m passionate about and often present in schools. What is your favorite movie? My favorite movie is “Remember the Titans.” It’s full of life lessons — and who doesn’t love a good football story? Tell us something about yourself most people don’t know. Something most people don’t know about me is that I’ve had many jobs and careers before discovering my passion for banking. I served as a police officer in Aspen and later as a reserve officer for the Weld County Sheriff’s Department, where I was part of the Warrant Task Force Unit. Mari Dhono Regional Operations Officer Bank of Colorado What is the most important thing you’ve learned from a career in banking? The most important thing I’ve learned from my career in banking is that success comes from a balance of knowledge, adaptability and persistence. Banking has taught me the importance of being open-minded when managing risks, continuously improving my understanding of financial products and economic trends, and embracing innovations like AI to stay ahead of change. At the same time, I’ve seen how transformational leadership and going above and beyond for customers create lasting trust and stronger relationships. Ultimately, my biggest lesson is that growth is a journey. If you don’t give up and always strive to be better, you not only achieve your own goals but also help your team, customers and organization succeed. What makes your bank unique? What makes Bank of Colorado unique is our ability to combine the strength and resources of a large financial institution with the personal service and community focus of a local bank. We pride ourselves on long-term relationships, not just transactions, and we empower our teams to know our customers personally. That blend of stability, innovation and hometown values truly sets us apart. What is the most rewarding aspect of your job? The most rewarding aspect of my job as a regional operations officer at Bank of Colorado is knowing that my work directly supports our teams and the communities we serve. It’s not just about keeping operations running smoothly; it’s about creating an environment where employees feel equipped and empowered to provide the best service to our customers. At the end of the day, it’s incredibly rewarding to see how the work behind the scenes translates into real impact of helping families, supporting local businesses and strengthening the trust our communities place in us. That sense of purpose and connection is what makes this role so meaningful for me. When you were a child, what did you want to be when you grew up? I always wanted to be an accountant. It’s a chance to crunch numbers and connect with people, helping them make sense of their finances in a way that actually makes their day easier. Tell us something about yourself most people don’t know. I moved to the United States in 2012, right after college and without speaking any English, just to experience what life here was like. Here I am 13 years later, loving every moment of life and thriving in my career at Bank of Colorado. 13 Colorado Banker
How Deposit Flows Are Reshaping the U.S. Banking Landscape By Tim Groth, Vice President, Data Analytics, IntraFi D eposit flows aren’t just a reflection of customer preferences; they also drive profitability, financial stability and lending capacity. When deposits move, they can affect balance sheet growth, increase credit availability and reshape the competitive landscape. It’s therefore notable that over the past five years, historic volatility has redistributed deposits among banks, with the smallest gaining the largest share. Deposit Growth Has Reaccelerated to a More Normalized Growth Path Following a Post‑COVID Stimulus Trough … As the accompanying chart shows, total domestic deposits surged during the pandemic and then declined sharply during the Fed’s tightening cycle. In late 2024, deposits began flowing back into banks as the Fed began softening its interest rate policy. By Q2 2025, after 100 basis points of cuts to the Fed funds rate, domestic deposits had grown by roughly $900 billion. … and Is Now Tracking Historical Growth Periods, Albeit at a Higher Starting Level This recovery has followed a stable trajectory, with a compound annual growth rate (CAGR) of approximately 3%, far more sustainable than the 16% CAGR during the pandemic and closer to the 5% CAGR seen before 2020. The aggregate deposit level has settled at $1.7 trillion above the pre-pandemic trend line. Punching Above Their Weight: Across Recent Periods, Community Banks Outperformed Their Larger Peers … While all bank size groups have grown deposits since the Q3 2023 bottom, community banks have gained the most relative to their size on a merger-adjusted basis. For instance, by Q2 2025, community and regional banks had fully recovered and posted net deposit gains, while Colorado Banker 14
super regional and money center banks had not yet regained the deposits lost during the downturn. Reciprocal deposits played a notable role in community banks’ deposit growth, representing $46 billion or 21% of their $222 billion increase during the industry growth period. … Which Drove Increases in Community Bank Market Share Community banks also gained market share during the decline and recovery. Before the pandemic, they held 14.8% of total domestic deposits. That share remained steady through the surge years but rose during the decline as larger banks lost ground and continued rising during the recovery. As of Q2 2025, community banks hold 16.6% of total domestic deposits. What Explains These Results, and Where Is Deposit Growth Going? Several factors likely contributed to the outperformance of smaller banks: • Product Promotion: Many community banks may have promoted more competitive deposit products, such as time deposits, to a greater extent than larger institutions. • Customer Relationships: Stronger ties with local customers may have helped them retain deposits. • Deposit Betas: Larger banks may have customers who are more sensitive to rising rates and did not raise their rates as fast as other alternatives, such as money market mutual funds. While these factors warrant further study, the data suggests that community banks, often assumed to be at a structural disadvantage, have proven more nimble in responding to shifting depositor behavior. Can Community Banks Hold Their Gains? Future outperformance isn’t a given. Larger banks could respond with aggressive pricing, digital strategies or other tactics to win back deposits. Indeed, 93% of respondents to IntraFi’s most recent quarterly survey of bank executives, the vast majority of which are community bankers, expect deposit competition to stay the same or intensify over the next 12 months.1 The institutions that come out ahead will be those attuned to how and why depositors move. Community banks, having gained ground during a period of heightened volatility, must try to sustain this momentum in a marketplace shaped by trust, convenience and evolving customer expectations. 1. Q2 2025 IntraFi Bank Executive Business Outlook Survey Since its founding over 20 years ago, IntraFi has been chosen by over 3,000 financial institutions. IntraFi’s deposit network is the largest of its kind, and its tested, trusted services help its network members acquire high-value relationships, fund more loans and seamlessly manage liquidity needs. IntraFi invented reciprocal deposits and is the No. 1 provider of deposit placement solutions, offering the largest per-depositor, per-bank capacity. 15 Colorado Banker
Multi-collateralized loans have gained traction in recent years as an attractive financing option for borrowers. By pledging multiple assets as security, borrowers can access larger loan amounts or secure more favorable terms than they might with a single-collateral loan. However, for lenders, this arrangement introduces a unique challenge, accurately tracking and managing the insurance coverage for each piece of collateral tied to a single loan. Without a robust tracking process, banks risk lapses in coverage, compliance issues and financial exposure. Why Borrowers Choose Multi‑Collateralized Loans Borrowers often choose multi-collateralized loans because they provide greater flexibility and enhanced borrowing power. By pledging multiple assets, borrowers can increase their overall loan amounts since the combined value supports higher lending limits. This approach also allows them to secure better terms, as additional collateral can translate into lower interest rates and more favorable conditions. For those who may not have enough equity in a single asset, multi-collateralized loans open the door to approval by leveraging additional property or holdings. For customers, it’s a clear advantage, but for lenders, it can present a unique operational challenge. Types of Collateral Used The assets used to secure multi-collateralized loans vary widely, including: • Real Estate: Commercial properties, residential homes or investment real estate. • Consumer Assets: Automobiles, boats, motorcycles, RVs, jet skis and similar vehicles. • Equipment: Machinery, technology or specialized tools. • Intangible Assets: Intellectual property, patents or certain financial instruments. Each asset has its own value, loan balance and insurance requirements. The mix of asset types creates complexity, as lenders must track multiple policies with different renewal dates, coverage limits and risk profiles, all under one loan agreement. Why Insurance Tracking Gets Complicated Tracking insurance for a single property is straightforward, but the process becomes much more complex when a loan involves multiple assets; for example, three vehicles, two pieces of equipment and a warehouse. The complications arise from several factors: Insurance requirements can differ depending on the asset type and jurisdiction, renewal dates may vary and increase the risk of missed deadlines, asset values often change and require updated coverage amounts, and inconsistent data formats between loan origination systems, collateral management tools and insurance tracking platforms create further challenges. Organizing Loan Information for Easier Tracking The key to managing multi-collateralized loans is data clarity. The more structured the information, the easier it is to automate and ensure compliance. Lenders should maintain: • Unique Identifiers for Each Collateral Item: A dedicated code for every asset tied to the loan. • Up-To-Date Status Information: Whether an asset is active, retired, sold or replaced. Insurance Tracking for MULTI‑COLLATERALIZED LOANS By MeKelee LaFoy, CP Insurance Associates Colorado Banker 16
• Accurate Value Tracking: Current valuations to ensure coverage meets lender requirements. • Clear Loan Allocation Details: How each asset’s value contributes to the overall loan balance. Unfortunately, many lender systems don’t natively output data in a format that insurance tracking platforms can use without manual intervention. In these cases, standardizing exports can reduce errors and administrative workload. The Benefits of Outsourcing Insurance Tracking Given the complexities of managing insurance across multiple asset types, many lenders find significant value in outsourcing tracking to specialized providers. Partnering with experts who offer dedicated insurance tracking services helps reduce the administrative burden and minimize the risk of errors or oversights. These providers not only streamline the process of monitoring different policies and renewal dates, but also ensure that coverage requirements remain consistent with lender standards and regulatory obligations. Another major advantage is the integration of automatic lender-placed insurance (LPI) coverage. When a borrower’s policy lapses or falls short of requirements, lenders can immediately place coverage to protect their financial interest without interruption. This reduces exposure to uninsured losses and helps maintain compliance while avoiding the delays of manual intervention. By leveraging outsourced solutions, lenders can turn a complex, high-risk operational challenge into a more seamless, reliable process. This approach allows financial institutions to focus their resources on customer service and loan growth, while still ensuring that collateral is adequately protected at every stage of the loan lifecycle. Final Thoughts Multi-collateralized loans give borrowers more options and lenders more security, if managed correctly. The complexity lies in keeping insurance coverage current for each pledged asset, and without the right processes in place, gaps can create real financial and compliance risks. While standardizing data, assigning unique identifiers and ensuring systems communicate effectively are important steps, lenders don’t have to manage this challenge alone. By outsourcing insurance tracking and leveraging automatic lender-placed insurance coverage, financial institutions can reduce risk, improve operational efficiency and ensure compliance with far less internal strain. With the right partners in place, banks can turn a potential headache into a well-managed lending advantage and focus more fully on serving their borrowers and growing their portfolios. 17 Colorado Banker
From SEO to GEO WHY BANKS MUST LEAD IN THE AGE OF AI SEARCH By Joe McMann, Co‑Founder & CRO, Artificial Intelligence Risk Inc. The Heartbeat of Communities Banks are more than financial institutions. They are neighbors, employers and champions of local progress. They sit at the crossroads of personal relationships and financial trust, ensuring that small businesses thrive, families can buy homes and local economies remain resilient. Unlike megabanks, banks derive their strength not from sheer scale but from their rootedness in people’s lives. But as the financial landscape changes, the way customers find and trust information about their banks is shifting dramatically. Just as the Yellow Pages gave way to Google two decades ago, today Google is giving way to generative AI search tools like ChatGPT, Claude and Perplexity. This transition — from search engine optimization (SEO) to generative engine optimization (GEO) — is not a passing fad. It represents a profound reshaping of how people get answers about who we are, what we do, and why they should trust us. For banks, the implications are immense. In a world where artificial intelligence is fast becoming the new “source of truth,” your digital footprint becomes your AI identity. The reputation built over generations of serving communities could be amplified — or undermined — depending on how well banks prepare for this transition. The SEO to GEO Shift: Faster Than the Yellow Pages to Google In the early 2000s, people slowly abandoned the Yellow Pages and shifted to online search. Google went from processing 18 million searches daily in 2000 to 14 billion today. The Yellow Pages, once found in 90% of American homes, had virtually disappeared by 2010. The shift we are seeing now, from SEO to GEO, is happening at lightning speed. Deloitte reports that 68% of Gen Z now prefer ChatGPT over Google for quick answers. McKinsey finds that nearly half of enterprise workers use generative AI weekly. Adoption that once took a decade is now occurring in less than three years. What this means for banks is that if your institution isn’t visible in AI answers, it risks invisibility altogether. A customer asking ChatGPT about the best mortgage lender in their county may never see your name — not because you aren’t the best, but because the AI hasn’t been trained to recognize your value. Why GEO Matters More for Banks Large national banks can spend billions on advertising, buy the top slots in Google search results and dominate through sheer financial muscle. Banks cannot — and should not — compete on those terms. Their strength lies in trust, local knowledge and authentic relationships. But generative AI changes the playing field. You cannot buy your way to the top of an AI answer. You earn it through clarity, trustworthiness and a well-positioned digital footprint. That’s where GEO comes in. For banks, GEO is about ensuring that when AI tools search the internet to answer questions like: “What bank supports small businesses in my town?” “Which local bank has the best track record in community involvement?” “Who can I trust with my mortgage?” ... The answers reflect your institution’s values, commitments and track record of community service Trusted Sources: The New Gatekeepers AI models don’t pull from everywhere equally. They rely heavily on a set of trusted sources — official websites, regulatory filings, press releases, respected news outlets and professional profiles like LinkedIn. For banks, this means: 1. Your website must be crystal clear. Schema markup, structured data and consistent messaging about your services, leadership and community involvement ensure AI can “understand” you. 2. Consistency matters. Information must align across LinkedIn, press releases, NCUA/FDIC filings and local news stories. Inconsistency raises red flags. 3. Third-party credibility is golden. Mentions in state banking associations, local news coverage and customer testimonials are not just good PR — they directly strengthen your GEO presence. In short: AI trusts what the community trusts. Banks already excel at being trusted in real life. Now they must translate that trust into digital form. Colorado Banker 18
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