OVER A CENTURY: BUILDING BETTER BANKS — Helping Coloradans Realize Dreams May/June OPENING ACCOUNTS ISN’T ENOUGH Why the First 90 Days Matter Most Meet Your 2026‑2027 CBA Officers Can Your AI Explain Itself? What Black Box AI Means for Financial Organizations
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©2026 The Colorado Bankers Association (CBA) | MBR Connect™, formerly The newsLINK Group LLC. All rights reserved. Colorado Banker is published six times per year 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 (801) 676-9722. Jenifer Waller President & CEO Alison Morgan Director of State Government Relations Brandon Knudtson CFO & Director of Membership Lindsay Muniz Vice President of Education and Communications Megan Carruth Executive Assistant Margie Mellenbruch Bookkeeper* Melanie Layton Lobbyist* Garin Vorthmann Lobbyist* Caroline Woodhouse Lobbyist* Michael McReynolds 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 6 20 2025-2026 Issue 6 4 CHAIRMAN’S MESSAGE An Honor and a Privilege By Brett Wyss, Outgoing Chairman, CBA 6 Opening Accounts Isn’t Enough Why the First 90 Days Matter Most By Amanda Marshall, Vice President of Marketing, ADVANTAGE 8 Utilizing Risk‑Mitigating Technology Closing the Gap and Strengthening Community Lending By Sherry Waner, Chief Development Officer, First Southwest Bank — a Community Development Financial Institution (CDFI) 10 No Hanging Up on the Phone Your Best Tool for Customer Service Is Evolving By Corey Wrinn, Managing Director, Rivel Banking Research 12 CBA Centerpoint Going Beyond the Desk to Hear the Stories of Colorado Bankers 13 Meet Your 2026-2027 CBA Officers 14 Three Questions Banks Should Ask About Moving Deposits Off Balance Sheet Moving Deposits Off Balance Sheet Is a Strategic Decision — Not a Reaction By H.D. Barkett, Senior Managing Director, IntraFi® 16 What the C-Suite Barometer Means for Bank Compliance Teams By Mark Burnside, CRCM, Director, ProBank Education Services, Forvis Mazars 18 Why Copilot Alone Is Incomplete for Community Banks And What Governed Intelligence Now Actually Requires By Joe McMann, Co-Founder and Chief Revenue Officer, Verapath 20 Why Clarity Will Define the Next Decade of Community Banking Relationships By Chris Myers, CEO, B:Side Capital 22 Can Your AI Explain Itself? What Black Box AI Means for Financial Organizations By Michael Berman, Ncontracts 24 Women in Banking Conference Aug. 3-4, 2026 3 Colorado Banker
As my term as chairman of the board for the Colorado Bankers Association comes to a close, I’ve spent a lot of time reflecting on what an incredible honor this experience has been. Serving as chairman during the 2025-2026 term gave me the opportunity to work alongside so many talented bankers, board members, staff, and industry partners who care deeply about Colorado’s banking industry and the communities we serve. I’m truly grateful for the relationships, conversations and experiences from this past year. When we started this term, we focused on a few key priorities: advocacy, education, financial strength and member engagement. Looking back, I’m proud of what we accomplished together. Advocacy remained one of our biggest focuses throughout the year as the industry continued to face new challenges and changes at both the state and federal levels. Thanks to the leadership and hard work of the CBA team, we continued to make sure Colorado bankers had a strong voice and a seat at the table on the issues that matter most. We also continued investing in education and leadership development for our members. Banking is constantly evolving, and helping bankers stay informed, connected and prepared for the future remains one of the most valuable services CBA provides. Another priority was maintaining the association’s financial strength so we can continue supporting our members and investing in programs and services that bring long-term value to the industry. Most importantly, this year reinforced how valuable the relationships within CBA truly are. The collaboration and support among Colorado bankers are something special. When our industry comes together, we’re able to accomplish so much more — for our banks, our customers and our communities. I sincerely thank the CBA staff, board members, committee volunteers, member banks and industry partners for all your support throughout this year. It has been a privilege to serve alongside you. While my term as chairman is ending, I’m excited about the future of both Colorado banking and the Colorado Bankers Association. I know the association will continue doing great things, and I’m grateful to have had the opportunity to be part of it. Thank you again for the opportunity to serve. CHAIRMAN’S MESSAGE An Honor and a Privilege By Brett Wyss, Outgoing Chairman, CBA Colorado Banker 4
| Bank Stock Loans | Loan Participations | ATM/Debit | International Services | | Cash Management | Securities Safekeeping | Merchant Services | 800-873-4722 | NE: 888-467-5544 | www.bbwest.com Where community banks bank Est. 1980 – Over 45 years of service to community banks “As a service provider exclusively focused on community banks, Bankers’ Bank of the West is here to help strengthen our clients and the communities they serve.” Across the western states and Great Plains, we’re the place where community banks bank. That’s because we provide the services, technology, and expertise to help you extend your resources, deliver for your customers, and stand out in your market. 5 reasons to partner with us BBW CEO and Vice Chair – Bill Mitchell 1. You can unlock efficiencies and cost savings. We can provide sophisticated solutions and economies of scale because we’re powered by hundreds of community banks across our region. 5. Our priorities are aligned with yours. 2. You can expand your capabilities. 4. We’ll never compete for your customers. 3. You can count on prompt, reliable service. • Independent loan review • Loan and credit administration consultation • Strategic planning facilitation • Management, staffing, & succession planning • Acquisition & expansion • BSA/AML compliance • Regulatory risk consultation President, Jim Swanson President, Anne Benigsen • Consulting • Phishing Tests • Vulnerability Management • Security Monitoring Cyber/information security, strategic planning, independent loan review, AND MORE. Consulting Services $ 8.45B assets under management $ 1.9B daily transaction value processed/settled Serving more than 60% of community banks across 7 states
A new checking account may look like growth on paper. Whether it becomes a primary relationship is what determines long-term value. Too many banks still treat a new checking account like a finished win. It isn’t. It is a start. That may sound obvious, but the way growth is often measured suggests otherwise. A campaign runs. New accounts come in. The numbers go on a dashboard. Leadership sees movement and assumes the strategy is working. But a new account and a primary relationship are not the same thing. That distinction matters more now because checking is no longer just a product line. It is the foundation of the relationship, linking income to spending, spending to saving and saving to borrowing. In a market where consumers often split their financial lives across multiple providers, the bank that wins the checking relationship is far more likely to win the broader relationship over time. This is where many growth strategies break down. Promotions, rate specials and short-term campaigns can all drive account openings. What they do not automatically drive is engagement. Without a deliberate plan behind the open, many of those accounts never become active, everyday relationships. The direct deposit never lands. The debit card never becomes the default card. Digital tools go unused. The account remains technically open, but strategically weak. That creates a false positive. Leadership sees new accounts and reads that as growth, even when the underlying relationship has not taken hold. The first 90 days is where the relationship is either won or lost. A better question is not, “How many accounts were opened?” It is, “How many of those accounts became meaningfully active in the first 90 days?” That early window tells the truth. If a new checking account establishes direct deposit, shows steady debit activity, begins using digital banking tools and starts building broader engagement, it is moving toward primary status. If those things do not happen, the account may be open without the relationship ever really taking hold. This is also why so many banks struggle to turn deposit growth priorities into real results. The strategy is often correct at a high level. Most bank leaders understand that checking matters. Where the gap shows up is in execution. Too often, banks invest in the front end of acquisition and underinvest in what happens next. They build the offer, fund the campaign and celebrate the open, but leave the onboarding experience to chance. That is where momentum gets lost. Sustainable growth does not come from generating interest alone. It comes from building a system that activates the relationship quickly and consistently. OPENING ACCOUNTS ISN’T ENOUGH Why the First 90 Days Matter Most By Amanda Marshall, Vice President of Marketing, ADVANTAGE Colorado Banker 6
5 Signs a New Checking Account Is Becoming a Primary Relationship 1. Direct deposit is established. 2. Debit card usage becomes consistent. 3. Alerts or digital banking tools are activated. 4. Bill pay or recurring payments are set up. 5. A second product or deeper engagement begins. The banks getting this right tend to do a few things differently. First, they define what a “primary relationship” actually means. They do not leave it as a vague aspiration. They tie it to observable behaviors such as direct deposit, transaction depth, digital engagement and multi-product adoption. Second, they stop relying only on campaign metrics and start measuring relationship metrics. Third, they build onboarding journeys designed to drive specific actions early, rather than sending generic welcome messages and hoping engagement follows. This shift also requires a broader mindset change. Growth cannot be treated as a series of isolated campaigns if consumer behavior does not work that way. People become open to switching every day — when they move, change jobs, grow frustrated or simply decide their current bank no longer meets their expectations. An always-on strategy is not about doing more marketing. It is about building the infrastructure to be present when those moments happen and then having the onboarding discipline to turn interest into primacy. Opening accounts is relatively easy. Turning those accounts into primary relationships is where the real work begins. For banks focused on long-term deposit growth, that is the shift that matters most. The goal is not simply to increase account volume. It is to build relationships that stay, deepen and matter. Amanda Marshall is a strategic marketing leader at ADVANTAGE with more than 15 years of experience helping financial institutions drive growth in regulated environments. She leads marketing strategy and customer engagement initiatives that help banks strengthen customer relationships through data-informed campaigns, measurable frameworks and long-term retention strategies. Learn more at advantage-fi.com. 7 Colorado Banker
By Sherry Waner, Chief Development Officer, First Southwest Bank — a Community Development Financial Institution (CDFI) As community bankers, we are the financial backbone of our neighborhoods. We understand firsthand that when local small businesses thrive, our communities prosper. We strive to help our entrepreneurs and small businesses, yet we are often constrained by lending parameters. It is a scenario familiar to every commercial lender: A promising entrepreneur walks through the door, but the deal quickly hits a wall. Perhaps it is a startup with limited operating history, a collateral shortfall, an inadequate down payment or a loan-to-value ratio past the comfort zone. When we are forced to turn these borrowers away, the ripple effects are felt far beyond our balance sheets. We lose the opportunity to spark job creation, and more importantly, we risk souring a customer relationship before it even has the chance to mature. Navigating the Complexity of Gap Funding Many lenders are aware that risk-mitigating enhancements exist — loan guarantees, down payment assistance, credit reserve programs and specialized grants. These tools are designed specifically to mitigate risk and bridge the gap for traditional banks. However, the barrier to entry is high. The sheer complexity, specialized reporting requirements and administrative overhead of these programs mean that many community banks simply do not have the resources to utilize them effectively. A Case Study in Creative Structuring A few years ago, our institution was approached regarding a business acquisition in southern Colorado. A military veteran, who had risen through the ranks as a sales representative, sought to purchase a local company, along with two other employees, that had been a staple employer in the region for over 30 years. It was a strong business with a proven legacy, but the buyers only had a 5% down payment. Under traditional underwriting, the financing was a non-starter. By leveraging risk-mitigating funding sources, we were able to structure a creative solution: 95% financing with a 75% guarantee on a nearly $2.5 million loan request. The deal closed; the veteran and two other employees became owners, and a vital local employer remained intact. Saying “Yes” More Often This success story became a catalyst for our organization. We realized that lenders across the Centennial State and beyond were facing the same hurdles. To solve this, we developed HelloBello®. HelloBello® is a technology platform built by bankers, for bankers. Using proprietary algorithms and logic, the platform identifies risk-mitigating capital and credit enhancements tailored to specific community projects and Utilizing Risk‑Mitigating Technology Closing the Gap and Strengthening Community Lending Colorado Banker 8
entrepreneurs who might otherwise fall through the cracks. In today’s competitive landscape, efficiency is everything. This technology simplifies the “alphabet soup” of complex lending programs, allowing community banks to deploy capital more effectively. By integrating these tools, we aren’t just managing risk — we are amplifying our impact, securing our margins and ensuring that the next generation of Colorado entrepreneurs has a seat at the table. If you want to learn more about how working with First Southwest Bank and HelloBello® can help your lenders say yes more often and expand access to capital in your communities, contact sherry.waner@fswb.com. 9 Colorado Banker
In an era where banks are investing millions into chatbots, self-service portals and AI-driven personalization, it’s easy to assume that digital convenience is the key to customer loyalty. But new findings from Rivel Banking Research suggest a more complex reality — one that bank marketers can’t afford to ignore. At a high level, the numbers look promising. A full 85% of Americans say they’re satisfied with their bank, and 94% rate their customer service positively. While it’s true that the industry seems like it’s delivering, when researchers dug deeper into actual service interactions, they uncovered a persistent pain point — response times. More than half of customers (58%) say their bank is too slow to respond when they need help. And that’s not just a minor inconvenience. It’s a moment of vulnerability, where frustration can quickly erode trust. These are the moments that matter most to consumers who are not interacting with their bank on a regular basis, and they’re often instances when loyalty is won or lost. For marketers, this presents a unique opportunity. Customer service isn’t just a support function; it’s brand experience and, frankly, one that carries substantial weight. Every interaction, especially those that happen under pressure, shapes how customers feel about your institution. And while advertising may build awareness, it’s the quality of service that builds lasting relationships, ensuring positive word of mouth. Why the Phone Still Rules In a world of digital-first solutions, it’s easy to assume that customers prefer chatbots, email or self-service portals when they need help. But when the stakes are high, like fraud alerts, declined cards or a missing payment, nearly half of customers still reach for the phone first. According to Rivel Banking Research, 46% of customers choose to call their bank first when they have a real problem, far ahead of email, chat or even branch visits. It’s not just about convenience for most consumers; it’s about reassurance. In moments of stress, people want to hear a voice, feel understood and know that someone is taking ownership of their issue. Here’s the complete ranking of how customers prefer to get help when they have a problem and need a quick solution, according to Rivel’s recent exclusive research for The Financial Brand: 1. Phone calls 2. Branch visits 3. Email 4. Chat 5. FAQ sections 6. Google searches The Service Reputation Game-Changer While many institutions are racing to optimize their digital channels, they may be neglecting the very touchpoint that drives the most meaningful brand impressions. This is where brand marketing comes in. Service quality can be a front-line differentiator, not just a back-office metric. In fact, 86% of potential customers, according to Rivel, say excellent customer service is a must-have when No Hanging Up on the Phone Your Best Tool for Customer Service Is Evolving By Corey Wrinn, Managing Director, Rivel Banking Research Colorado Banker 10
choosing a financial institution, second only to trustworthiness. Before they compare rates or product features, they’re evaluating how your institution treats people when things go wrong. Yet too often, customer service is treated as a cost center rather than a brand asset. Imagine this: A customer calls your competitor at 7 p.m. about a declined debit card. They’re transferred three times, wait on hold and finally reach someone who can’t resolve the issue. That frustrating experience doesn’t just damage loyalty; it creates an opening for you. If your institution can deliver fast, empathetic and effective service in that moment, you’ve done more than solve a problem — you’ve earned trust. For institutions looking to stand out, this is the untapped opportunity. The phone isn’t outdated; it’s underleveraged as a tool for customer service and ultimately your reputation. In a landscape where differentiation is hard to come by, responsiveness is your most human — and most powerful — advantage. Some Banks Are Blending Human Touch with Technology The leading institutions aren’t going all digital or staying stuck in the past using old tools. They’re relying on new technology to make their human interactions even better. Let AI Handle All the Routine Stuff Use automation for routine tasks such as account balance checks and password resets. This frees your human staff to handle complex situations that require empathy and real problem-solving. It’s not about replacing people, it’s about freeing them to do what they do best. Make It Personal Customers expect interactions tailored to their specific needs. Banks using smart personalization see click-through rates jump by 500% because they’re presenting the right solution at exactly the right moment. Human-Empowered Model Many leading banks are shifting focus from customer-facing chatbots to internal AI tools that support their employees. By using generative AI to summarize documents or surface relevant insights, staff can respond faster and more effectively to client needs. For marketers, it’s a reminder that great customer experiences often start behind the scenes and need to be shared to be understood. This type of shift is already happening. Oswego County FCU, a credit union in upstate New York, is proving how AI can elevate the member experience without losing the human touch. As CEO Bill Carhart explains: “The Credit Union launched an AI-driven phone system in February of this year. To date, we have handled over 55,000 calls with a fully automated call rate ramping up to about 25% of all calls handled by AVA, our system attendant. Even more valuable is that over 4,800 calls have been handled after hours, creating a true 24/7 experience for our members.” Your Action Plan to Win the Service Reputation Game Every customer interaction your team handles is a potential marketing story. Here’s how to capture and use them. Market Solutions, Not Features Don’t advertise “24/7 chatbots.” Market “quick answers at 2 a.m. when you’re stuck in another time zone.” Find specific customer pain points and build your messaging around solving them. Get Ahead of Problems Use customer data to solve issues before they happen. Send fraud alerts, provide spending insights and offer relevant financial guidance based on what you already know. Then market your proactive approach as what sets you apart. Showcase the Human Moments Document when your team goes above and beyond. Collect thank you messages from grateful customers. A video testimonial about resolving a vacation emergency beats most rate comparison campaigns you could create. Measure What Matters Track the problems your team solves and the relationships they build. These stories become proof points that your service claims are real, not just marketing fluff. While competitors spend millions trying to convince customers they offer great service, you have the chance to prove it — one call, one resolution and one story at a time. The phone isn’t going away. Neither is the need for human connection. In fact, as digital channels multiply, the institutions that master the fundamentals, such as responding quickly, solving completely and showing up with empathy, will stand out even more. In the end, your phone might not just be a support tool. It could be your most powerful marketing asset. Turning Support into Brand Equity Consumers and businesses will always be looking for competitive rates and low fees, but you can stand out from the crowd by actually fulfilling the requirement of good service. Local banks and credit unions already have proximity and personal relationships on their side. But to turn that into sustained growth, it’s not enough to sponsor events or support local causes — you need to show up when it matters most. This is where brand and service intersect. Customers remember how they’re treated in moments of stress, and those experiences shape how your institution is perceived. When your team delivers consistently, you’re reinforcing your brand promise. In a competitive environment where digital tools are everywhere, being the institution that answers, listens and acts locally is a differentiator and growth strategy, but the message needs to be shared with those who don’t yet know how you can help. For more information on Rivel Banking Research’s benchmarking, market opportunity highlights and on-hand brand perception insights for your institution, contact Corey Wrinn, managing director, Rivel Banking Research, at cwrinn@rivel.com. 11 Colorado Banker
Trent Witt VP, Colorado Market Retail Leader KeyBank What is the most rewarding aspect of your job? I’ve been in banking at KeyBank for over 16 years, and the most rewarding part of my job has always been the people. Not just helping clients, but watching teammates grow, build confidence and accomplish things they didn’t think were possible. There’s nothing better than seeing someone you’ve coached step into a bigger role. What are you most proud of in your professional life so far? What I’m most proud of isn’t a single metric or award, but the culture we’ve built across our teams. We’ve created an environment where people genuinely care about each other, push each other to be better and still have fun doing it. When you get that right, the results tend to follow. What is the most important thing you’ve learned from a career in banking? If there’s one thing banking has taught me, it’s that this business is really about trust and relationships. Products and rates change, but if you show up consistently, do the right thing and put people first, you’ll build something that lasts. That applies to leadership as well. When you were a child, what did you want to be when you grew up? When I was younger, I wanted to be an elementary school teacher. I’ve always enjoyed helping people learn and grow. I actually started at KeyBank while finishing my degree and quickly saw that banking provided a similar opportunity. I was able to teach clients about money and finances, which are critical parts of everyday life yet are often not taught. What do you geek out about? Outside of work, I probably geek out the most about personal finance and investing. I genuinely enjoy talking about ways people can grow their money and set themselves up for the future. I also spend a lot of time staying active, skiing when I can and hanging out with my son, which is always the best part of my week. CBA Centerpoint GOING BEYOND THE DESK TO HEAR THE STORIES OF COLORADO BANKERS Ryan Kato Chief Operating Officer Integrity Bank & Trust How did you get started in the banking industry? My path into banking was not traditional. Before banking, I worked in retail sales, served as an assistant funeral director, bartended and tried my hand at entrepreneurship. Eventually, one of my mentors, who owned a one-branch bank in Grandview, Ohio, introduced me to the industry. Something clicked. Banking’s combination of people, numbers, business, problem-solving and community impact pulled me in. I also saw an industry with room to evolve. Honoring what community banking does well while helping it become faster, smarter and more relevant still energizes me today. What makes your bank unique? Integrity Bank & Trust feels different because its values are not performative. Service, excellence and teamwork, or S.E.T., are visible every day in how employees treat customers and one another. I noticed that quickly. The bank’s commitment to Colorado Springs also stands out. Through our charitable trust, a portion of profits supports nonprofits doing meaningful work here. Community banks should be force multipliers for the community around them. What is the most important thing you’ve learned from a career in banking? People don’t really want banking products; they want what those products make possible. Nobody wakes up excited about treasury management, but they do want their business to run better. Nobody dreams about a mortgage, but they do dream about owning a home. That mindset forces you to listen more than you speak. Banking can get bogged down by acronyms, policies and the way things have always been done. The future belongs to people who can make it less intimidating and more connected to real life. What do you geek out about? I geek out about data, but not because I love spreadsheets for their own sake. I love what data can reveal: patterns, friction, opportunities and the gap between what we think is happening and what actually is. Rather than letting data replace human judgment, it should sharpen our judgment and help us ask better questions. Colorado Banker 12
The Colorado Bankers Association hosted its annual membership meeting on Friday, May 22, during which new officers were elected by unanimous vote to lead CBA for the 2026-2027 term. Jennifer Luce, executive vice president at FirstBank, now part of PNC, will serve as CBA chairman. Matthew Propst, senior vice president, credit risk review manager at ANB Bank, is the new chairman-elect, and John Berkhausen, president of commercial banking at Adams Bank & Trust, will serve as treasurer. “I am honored to serve as chairman of the Colorado Bankers Association Board,” Luce said. “Jen Waller and the CBA staff do outstanding work and are strong advocates for the banking industry. I look forward to working alongside them in the year ahead. As board chair, I will focus on deepening community impact and collaboration, strengthening membership across our state footprint, enhancing strategic relationships with legislators and supporting sustainable, member-driven political action efforts. Through these priorities, we can amplify our collective voice in support of the banking industry and the communities we serve.” “Serving as an officer of the CBA Board provides an even greater opportunity to help shape the direction of the industry and advocate on behalf of Colorado’s banks and the communities they serve,” said Jenifer Waller, CBA president and CEO. “Strong leadership and active engagement at every level of the board are more important than ever.” Jennifer Luce, FirstBank, now part of PNC, CBA Chairman Jennifer Luce is executive vice president at FirstBank, now part of PNC, where she leads the South Metro market in Colorado. With more than 25 years in commercial banking, she has built a career at the intersection of finance, real estate development and community impact. A recognized leader in both banking and real estate, Jennifer also serves as president of CREW Denver and has long been engaged in economic development, housing and policy work. Her commitment to advancing women and strengthening communities is reflected in her extensive board service, including the Colorado Secure Savings Program, the Castle Rock Economic Development Council and the Colorado Community Land Trust. She has been honored as an Outstanding Woman in Banking and a CBA Banker of Distinction. Matthew Propst, ANB Bank, CBA Chairman-Elect Matthew Propst is senior vice president and credit risk review manager for ANB Bank. His experience, industry knowledge and service focused approach support strong outcomes for customers and the community. Previously, he served as community bank president for the Denver Tech Center location. Matthew holds a Bachelor of Science in finance with an emphasis in corporate finance and is a graduate of the Graduate School of Banking at Colorado. He also completed the CBA Advocacy program. He is active in the community through board roles with the Tennyson Center for Children (finance chair), Cherry Creek Schools Foundation and the Colorado SecureSavings Program. Nationally, he serves on the ABA Government Relations Council. John Berkhausen, Adams Bank & Trust, CBA Treasurer John Berkhausen grew up in Southern California and earned a Bachelor of Science in economics from Boston College. After a year with the Jesuit Volunteer Corps in San Francisco, he attended Creighton University, earning both his Juris Doctor and MBA. He began his career in First National Bank of Omaha’s executive development program, later becoming a corporate banker and helping expand the bank’s correspondent banking presence in Colorado. In 2013, he joined Cache Bank & Trust as market president. He moved to Adams Bank & Trust in 2020, where he now serves as president of commercial banking, overseeing commercial lending, business deposits, SBA lending and treasury management. John lives in Fort Collins with his four daughters and enjoys outdoor activities and supporting his kids’ pursuits. 2026-2027 CBA Officers Meet Your 13 Colorado Banker
THREE QUESTIONS BANKS SHOULD ASK About Moving Deposits Off Balance Sheet Moving Deposits Off Balance Sheet Is a Strategic Decision — Not a Reaction By H.D. Barkett, Senior Managing Director, IntraFi® Deposit networks are often described as funding tools, enabling banks to access funds and depositors to access FDIC insurance on large amounts. But they are far more than that. Deposit networks can also be balance sheet levers — mechanisms that allow banks to manage timing, risk and optionality without sacrificing customer relationships. One crucial benefit offered by deposit networks is flexible liquidity management — including the opportunity to move deposits off balance sheet by selling them to network banks in exchange for fee income while retaining the customer relationship. There are several reasons why your bank might consider moving deposits off balance sheet: • Liquidity surges that outpace near-term loan demand • Timing mismatches between asset growth and deposit inflows • Heightened scrutiny of uninsured deposits and concentration risk following banking stress events • Regulatory attention to large depositors and funding stability When facing these circumstances, partnering with a large-capacity, established bank network to move deposits off balance sheet can give your bank a competitive advantage by creating flexible liquidity. By treating moving deposits off balance sheet as a strategic decision, rather than as a reactive outlet for excess balances, your bank can profitably retain control over future growth. The question is not whether your bank should move deposits off balance sheet — but when, why, and under what constraints. That starts with three core questions. Question #1: What Opportunities Can Be Created by Moving Deposits Off Balance Sheet? Your bank can profitably move deposits off balance sheet for a number of reasons, including: • Managing deposit concentration limits, especially tied to large commercial or municipal accounts • Smoothing out seasonal or event-driven liquidity surges • Controlling where the bank stands relative to key asset, reporting or regulatory thresholds • Compensating for temporary mismatches between deposit inflows and loan demand Colorado Banker 14
Federal banking regulators have made clear that large depositors and uninsured balances warrant prudent management.1 Selling deposits to other banks in a deposit network allows your bank to retain the customer relationship while addressing balance-sheet, liquidity and regulatory pressures — moving the funding, not the depositor relationship. Question #2: What Economic and Pricing Guardrails Should Be Considered? Are you getting paid appropriately to move deposits off balance sheet? At its core, the economics hinge on three variables: 1. The rate paid to the customer 2. The applicable deposit sell rate 3. The resulting spread and fee income Defining these up front, alongside the amount of deposits to be sold, helps ensure profitability. Establishing Pricing Guardrails Effective programs define clear guardrails, including minimum acceptable spread thresholds, and establish competitive monitoring to ensure pricing and market rate changes do not undermine the relationship. Market volatility makes static assumptions dangerous. As interest rates change, economics that once worked can quietly deteriorate unless actively reviewed. Governance and Accountability Strong governance can position your bank to make strategic, rather than reactive, decisions to move deposits off balance sheet. A best practice is to establish clear ownership of pricing decisions — your bank’s asset-liability committee is one possible owner — and a defined approval path for exceptions to ensure that your deposits are priced intentionally, not deployed reflexively. Question #3: Are You Operationally Ready — and Able to Pivot Back? Regulators increasingly expect deposit programs to be repeatable and auditable. To ensure you can start moving deposits off balance sheet without issue, ensure your bank has assembled and codified the following: • Customer consent and disclosures • Documentation and reporting accuracy • Settlement and reconciliation workflows • Clear ownership across treasury, operations and relationship teams Define the Trigger to Move Deposits Off Balance Sheet — Before You Need It Before moving deposits off balance sheet, clearly define the dollar magnitude of a given sell trigger, the consequences of keeping deposits on balance sheet and the expected duration of funds moved off balance sheet — weeks, quarters or a defined strategic window. Plan Your Exit Before Entry The most disciplined institutions define exit triggers in advance. These could include increasing loan demand, on-balance-sheet funding regaining strategic value or other changes in liquidity or capital needs. Moving Deposits Off Balance Sheet Is a Powerful Option When your bank needs more liquidity, it’s much easier to redeploy deposits from existing customers than it is to source new relationship deposits. Deposit networks make that flexibility possible. Other cash management offerings for customers, such as money market mutual funds and wholesale funding, are less flexible and more expensive. Ultimately, deposit networks (and using them to move deposits off balance sheet) are about control and timing. Banks that successfully use their deposit network as a liquidity management tool consistently ask: 1. What issue are we solving? 2. Are the economics disciplined and defensible? 3. Can we execute cleanly — and exit deliberately? Used well, an off-balance-sheet strategy can allow your bank to win relationships and manage risk today and preserve the option to fund growth tomorrow. That optionality is the true value of a deposit network. IntraFi operates a deposit network of 3,000+ members and offers the highest per-depositor and per-bank capacity in the industry. For more than 23 years, banks have relied on IntraFi’s on-balance-sheet (reciprocal deposits and wholesale funding) and off-balance-sheet (One-Way Sell®) solutions to strategically manage liquidity, grow customer relationships and increase profitability. Deposit placement through IntraFi Services is subject to the terms, conditions and disclosures in applicable agreements. IntraFi is not an FDIC-insured bank, and deposit insurance covers the failure of an insured bank. A list identifying IntraFi network banks appears at intrafi.com/network-banks. Certain conditions must be satisfied for “pass-through” FDIC deposit insurance coverage to apply. 1 Federal Deposit Insurance Corporation, “Section 6.1: Liquidity and Funds Management,” in Risk Management Manual of Examination Policies, https://www.fdic.gov/risk-management-manual-examination-policies/section-61-liquidity-and-funds-management.pdf; “RISK MANAGEMENT—Interagency Policy Statement on Funding and Liquidity Risk Management,” https://www.federalreserve.gov/frrs/guidance/interagency-policy-statement-on-funding-and-liquidity-risk-management.htm#ANCHOR1. 15 Colorado Banker
Executive perspectives across regional and community banks reflect a thoughtful approach as leaders navigate regulatory pressures and accelerated change across the industry. According to the “C-Suite Barometer: Executive Leadership Insights in the US,” organizations are maintaining progress by pairing technology investment with disciplined execution and operational adaptability. For regional banks, this focus exists alongside a familiar reality. Examiner expectations continue to rise, technology risk is changing, and internal resources remain constrained. In this environment, bank compliance teams are no longer viewed solely as risk gatekeepers. In addition, they’re also increasingly expected to support informed execution and help leadership move forward with clarity while maintaining regulatory readiness. Why Is Adaptability Critical for Compliance Risk Management? The C-Suite Barometer indicated that executives were entering 2026 with confidence, driven by a willingness to act in uncertain conditions. Adaptability, rather than caution alone, is shaping leadership decision-making. For regional bank compliance teams, adaptability extends beyond updating policies after guidance is finalized or delivering one-time training. Regulatory expectations shift frequently, often between examination cycles. Compliance teams are responsible for interpreting new guidance, translating expectations into practice and supporting consistent application across lines of business. Ongoing learning is essential in this environment to help compliance professionals stay current, apply judgment consistently and support their organization as strategies, products and processes change. Adaptability then becomes more of an operational discipline instead of a reactive response. AI and Technology Transformation: New Challenges for Compliance Teams Technology transformation remains a top strategic priority as artificial intelligence (AI) moves from experimentation into daily use. Even if they haven’t formally launched an AI program, banks are already using AI-enabled capabilities in many cases. These capabilities may exist within third-party platforms, underwriting tools, customer relationship management (CRM) systems or portfolio management applications. This reality introduces new compliance considerations for regional and community banks. As AI-supported tools influence internal decisions, regulators expect institutions to understand how outputs are generated, where the underlying data originate and whether decisions can be supported by documentation and audit trails. Data quality and traceability are emerging as significant risk areas. When AI-enabled tools generate narratives, assessments or insights, compliance teams need to address foundational questions, such as: • Where did the information originate? • Is it verified? • Can it be reproduced? • Can it be supported during an examination? What the C-Suite Barometer Means for Bank Compliance Teams By Mark Burnside, CRCM, Director, ProBank Education Services, Forvis Mazars Colorado Banker 16
Examiners are unlikely to accept incomplete explanations or undocumented assumptions. Governance-grade use of AI depends on validated data sources, defined oversight and clear accountability. Approaches that emphasize controlled retrieval from approved data sets, rather than unrestricted content generation, can help reduce risk, support examiner expectations and discourage the use of unapproved tools outside established governance processes. Moreover, education that is aligned with AI governance can help compliance teams support responsible innovation without introducing unnecessary regulatory exposure. Workforce Readiness: A Strategic Priority for Bank Compliance The C-Suite Barometer highlights sustained investment in both technology and talent, alongside continued challenges in attracting and retaining skilled professionals. For regional banks, workforce readiness is often less about net new hiring and more about strengthening existing teams. Compliance, risk, audit and operations professionals are frequently asked to take on broader responsibilities as systems, products and regulatory requirements evolve. Targeted education can help close knowledge gaps, promote consistent control application, and support engagement and retention. Board members are increasingly viewing workforce development as a risk management strategy that enables an institution to scale change without creating compliance blind spots. How Do Strong Governance and Controls Drive Compliance Success? Executives are recognizing that innovation succeeds when paired with robust controls, thoughtful execution and clear strategic direction. Confidence is driven by operational clarity rather than risk avoidance. Strong governance for regional bank compliance teams extends beyond documented policies and procedures; they rely on people. Well-prepared teams apply judgment consistently, understand regulatory intent and respond effectively to examiner inquiries. As AI and automation become more integrated into daily workflows, controls increasingly depend on data governance, documentation standards and the ability to explain how insights were produced, not just the outcomes. Ongoing education can strengthen these practices and serve as a foundational component of enterprise risk management. Preparing for Regulatory Pressure: A Compliance Road Map The C-Suite Barometer reflects an executive mindset that anticipates continued regulatory and external pressure. Preparation, rather than reaction, supports confidence, particularly in banking environments where supervisory expectations continue to rise. Regional bank compliance teams that adopt continual learning approaches are better positioned to demonstrate readiness, respond to evolving guidance and support leadership decision-making during periods of change. What Does This Mean for Bank Compliance Teams Going Forward? The findings from the C-Suite Barometer reinforce several critical priorities and challenges that regional and community bank compliance teams need to address to stay ahead: • Adaptability is essential in a dynamic regulatory environment. • Technology adoption, including AI, introduces new governance and data risks. • Workforce development is a strategic priority, not a support function. • Strong controls depend on informed and consistent application. • Confidence grows through preparation supported by continual education. As regional bank leaders focus on disciplined execution and future-ready operations, compliance education plays a critical role in helping mitigate risk and supporting innovation. How Forvis Mazars Can Help ProBank Education Services at Forvis Mazars has been helping drive performance in the financial services industry through educational compliance training and resources for more than 40 years. Our team supports compliance at financial institutions by delivering insightful education that aligns compliance, risk and operations teams with evolving regulatory and examiner expectations. Through structured programs focused on technology, risk and applied judgment, ProBank Education Services professionals can help teams make informed decisions, explain processes and respond confidently during examinations. Connect with professionals at Forvis Mazars today to learn more about ProBank Education Services. Mark Burnside, a director at Forvis Mazars in the ProBank Education Services division, has more than 26 years of experience in the financial services industry with a focus on regulatory compliance. He has spent over 16 years as a compliance consultant assisting financial institutions with BSA/AML, Fair Lending, Lending and Deposit requirements. Mark has worked on projects for both community and national institutions, and has facilitated training and oversight processes from risk assessments to compliance management systems. He is a graduate of Indiana University with a bachelor’s degree in economics. He is also a Certified Regulatory Compliance Manager (CRCM). 17 Colorado Banker
Community banks are under increasing pressure to adopt artificial intelligence. That pressure is justified. Intelligence already shapes how information is interpreted, how risk is assessed and how decisions are made inside financial institutions. What is no longer optional is whether bank intelligence is governed, supervised and defensible. Microsoft Copilot is often presented as the safest place to begin. It feels familiar. It operates inside platforms banks already trust. For many institutions, it appears to offer a controlled entry point into AI without introducing new exposure. However, that specific framing does not survive institutional scrutiny. To be clear, Copilot is not flawed because Microsoft is untrustworthy. The limitation is architectural as Copilot was not designed for regulated institutions that must explain, supervise and defend how intelligence behaves once it becomes part of the bank’s operating environment. Artificial intelligence is an operating capability. Any system that influences judgment inside a bank is part of the bank’s control environment. Once AI enters that environment, governance is no longer a policy choice. It is an operating requirement. Copilot is typically adopted as a licensing decision, which creates the first failure. Licensing software is an IT action, but deploying intelligence is an institutional one. When those actions are treated as equivalent, accountability collapses before the system ever produces an outcome. • No governing body owns results. • No standards define acceptable behavior. • No structure exists to observe drift or intervene when exposure emerges. Strategic AI decisions cannot sit with IT, vendors or end users. Strategic AI decisions must sit with management. In many community banks, AI responsibility can default to technology, but IT manages systems while AI governs judgment. Judgment influences lending, compliance, customer treatment and operations. These are not technical outcomes. They are enterprise outcomes, and they will surface at the institutional level under examination regardless of where responsibility was assigned. One of Copilot’s defining limitations is model capabilities and control. Copilot binds the bank to a single vendor’s model ecosystem and does not allow for a model to be directly correlated and optimized for a specific use case. Community banks cannot: • Select different models across all approved model providers • Hold model behavior constant while evaluating outcomes • Control when models change and/or how those changes affect reasoning Model choice is not a technical preference. It is a governance decision. Different banking activities require different reasoning behaviors. Lending review is not policy interpretation. Customer communication is not compliance validation. When intelligence flows through a single model, errors Why Copilot Alone Is Incomplete Incomplete for Community Banks And What Governed Intelligence Now Actually Requires By Joe McMann, Co-Founder and Chief Revenue Officer, Verapath Colorado Banker 18
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