July/August 2026-2027 CBA Chairman JENNIFER LUCE PNC BANK OVER A CENTURY: BUILDING BETTER BANKS — Helping Coloradans Realize Dreams
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©2026 The Colorado Bankers Association (CBA) | MBR Connect™. 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 5 19 2026-2027 Issue 1 4 CHAIRMAN’S MESSAGE Strong Connections, Strong Communities By Jennifer Luce, Chairman, CBA 5 Recognizing Elder Financial Exploitation Protective Practices for Financial Institutions By Mark W. Dever, AAP, CAMS, ProBank Education Services Director, Forvis Mazars 7 B:Side Assist Launches AI-Powered Financial Platform for Small Business Owners By B:Side 8 250 Years of Betting on the American Dream By MeKelee LaFoy, Business Development Representative, CP Insurance Associates 10 Driving Community Prosperity With Reciprocal Deposits By Joe Hooker, Chief Sales Officer, IntraFi 13 CBA Centerpoint 14 Why Overdraft Should Be Managed as a Service Line By Cheryl Lawson, Executive Vice President of Compliance Review, ADVANTAGE 16 AI Deployment in Financial Institutions Why Some Banks Succeed While Others Don’t By Michael Goh, Cofounder and CEO, Krew 19 Third-Party Ownership: A New Opportunity for Banks How Residential Solar Portfolios Are Expanding Access to Investment Tax Credits By Rob Holzman, Chief Strategy Officer, Lumifi Corporation 21 Strengthening Rural Communities Through Partnership By Rocky Mountain Farmers Union 3 Colorado Banker
CHAIRMAN’S MESSAGE Strong Connections, Strong Communities It is an incredible honor to serve as chairman of the Colorado Bankers Association for 2026-2027. I am grateful for the trust of my fellow bankers and look forward to building on the strong foundation established by the outstanding leaders who have served before me. Banking has always been about more than financial transactions. At its core, banking is about relationships — helping families achieve their dreams, supporting businesses that drive our local economies and strengthening the communities we proudly call home. As our industry continues to evolve, so too must the way we collaborate, advocate and lead. This year, my focus centers on four strategic priorities that I believe will strengthen both our association and the banking industry across Colorado. Collaborating for Greater Community Impact Colorado banks have a long history of investing in the people and places they serve. From financing small businesses and affordable housing to promoting financial literacy and volunteerism, our industry creates a lasting impact every day. Together, we have an opportunity to further elevate that work by strengthening partnerships, sharing our collective success stories and reinforcing the value of relationship banking throughout our state. Expanding Membership Across Colorado The Colorado Bankers Association is strongest when every member bank has a seat at the table. Whether serving a rural farming community, a growing mountain town or a major metropolitan market, every institution brings valuable perspective and expertise. My goal is to deepen engagement across every region of Colorado, ensuring banks of all sizes feel connected, represented and empowered to help shape the future of our association. Enhancing Strategic Relationships With Policymakers Advocacy remains one of the CBA’s most important responsibilities. Building meaningful relationships with state and federal legislators allows us to effectively communicate the essential role banks play in supporting Colorado’s economy. By increasing outreach, encouraging ongoing dialogue and creating opportunities for legislators to experience firsthand the impact banks have within their communities, we can help inform policy discussions that benefit consumers, businesses and our industry alike. Strengthening Advocacy Through Member Support Strong advocacy requires sustained investment. A healthy, member-supported Political Action Committee (PAC) provides the resources necessary to ensure the banking industry’s perspective is represented at the Capitol. Expanding participation across our member banks will strengthen our ability to advocate for policies that foster economic growth, preserve a healthy banking environment and protect the communities we serve. These priorities share a common theme: connection. By strengthening relationships — with our communities, our member banks, our elected officials and one another — we position Colorado’s banking industry for continued success. I am excited for the year ahead and look forward to working alongside our dedicated CBA Board of Directors, staff, member banks and industry partners. Together, we will continue advancing an industry that serves as the financial backbone of Colorado while ensuring the Colorado Bankers Association remains a trusted, unified voice for banking across our great state. Thank you for the opportunity to serve. I look forward to all we will accomplish together. By Jennifer Luce, Chairman, CBA Colorado Banker 4
Recognizing Elder Financial Exploitation Protective Practices for Financial Institutions By Mark W. Dever, AAP, CAMS, ProBank Education Services Director, Forvis Mazars The National Adult Protective Services Association defines elder financial exploitation (EFE) as the “illegal or improper use of an older person’s or vulnerable adult’s funds, property or assets.”1 EFE is one type of elder abuse, which includes physical, sexual, emotional or psychological, and financial abuse or exploitation, neglect, abandonment and/or self-neglect.2 This article will explore EFE schemes and actions for financial institutions to consider. EFE Schemes to Watch For EFE includes the use of deception, intimidation or undue influence by a person or entity in a position of trust and confidence with an elderly person to obtain or use the property, income, resources or trust funds of the elderly person for the benefit of a person or entity other than the elderly person; the breach of a fiduciary duty, including, but not limited to, the misuse of a power of attorney, trust or a guardianship appointment, that results in the unauthorized appropriation, sale or transfer of the property, income, resources or trust funds of the elderly person for the benefit of a person or entity other that the elderly person; and obtaining or using an elderly person’s property, income, resources or trust funds without lawful authority, by a person or entity who knows or clearly should know that the elderly person lacks the capacity to consent to the release of use of their property, income, resources or trust funds.1 EFE schemes generally involve either elder theft (schemes involving the theft of an older adult’s assets, funds or income by a trusted person; in many instances, an adult child or a close friend) or elder scams (scams involving the transfer of money to a stranger or imposter for a promised benefit or good that the older adult did not receive).3 Older Adults Are Losing More Money to Scams The U.S. Census Bureau currently estimates the total U.S. population at approximately 342.6 million persons (approximately 4.2% of the estimated world population).4 The National Council on Aging estimates that between 18-19% of the population is age 60 and over, and that group controls an 5 Colorado Banker
estimated 70% of the nation’s invested wealth, making elderly adults prime targets for fraudsters.5 According to the National Money Laundering Risk Assessment, fraud remains the number one predicate crime in the U.S. today.6 In addition, in its most recent annual report to Congress on the agency’s actions to protect older adults, the Federal Trade Commission (FTC) reported that total fraud losses reported by older adults increased almost fourfold from 2020 to 2024 ($600 million to $2.4 billion), largely driven by reports of losses exceeding $100,000, often to investment scams, romance scams or impersonations, e.g., government, business, family (grandparent), friends, et al.7 In 2024, older adults reported losing far more money to investment scams than to any other fraud type, often reporting that the scammers targeted them on social media. In April 2026, the FTC reported that social media scams resulted in far more losses than any other contact method scammers used to reach consumers.8 Reports show that in 2025, people reported losing more money to scams that started on Facebook than on any other social media platform. The data also show that all age groups, except those 80 and over, reported losing more money to scams that started on social media than to any other contact method, and social media ranked second only to phone calls for those 80 and over. In its recent Internet Crime Report, the FBI’s Internet Crime Complaint Center (IC3) reported that 20% of the record 1 million complaints received in 2025 were from consumers age 60 and over, with that population suffering 37% of the total $20.8 billion reported losses.9 Practices for Institutions to Consider The five financial regulatory agencies have provided examples of risk management and other practices for financial institutions that may help combat EFE, including: • Train employees on recognizing and responding to EFE • Use transaction holds and disbursement delays, as appropriate and consistent with applicable law • Establish a trusted contact designation process for account holders • Report suspected EFE to law enforcement, Adult Protective Services and other appropriate entities • Engage with elder fraud prevention and response networks • File suspicious activity reports (SARs) in a timely manner • Increase awareness through consumer outreach Various government agencies provide tools and resources to help older clients either avoid becoming victims or recover when the fraud has occurred, including: • The FTC publishes a variety of consumer alerts to raise awareness of the latest fraud techniques and maintains a plethora of “fact sheets” addressing fraud trends to help educate elderly clients as part of the FTC’s Pass It On education campaign. • The U.S. Department of Justice maintains the Elder Justice Initiative with links to the various state agencies that can assist elderly victims and manages the National Elder Fraud Hotline at (833) 372-8311. • The Consumer Financial Protection Bureau (CFPB) has developed materials to help a financial institution establish a “trusted contact” program. How Forvis Mazars Can Help With 7.9% of SARs filed in the first quarter of 2026 referencing EFE, it is important that financial institutions adopt policies and procedures to protect their elderly clients from financial exploitation.10 Our ProBank Education Services team at Forvis Mazars can help your institution navigate regulatory compliance. If you have any questions or need assistance, please reach out to one of our professionals. For more information, scan the QR code to watch our on-demand webinar, “Elder Financial Exploitation (EFE) ― Updated Fincen Guidance.” https://www.probank.com/product/elder-financialexploitation-efe-updated-fincen-guidance/ Mark W. Dever, AAP, CAMS, is a director at Forvis Mazars. Prior to joining the firm in 1996, Dever was vice president and manager of cash management operations for a multibillion-dollar regional bank holding company with several affiliates. He has extensive experience in many areas, including the automated clearing house (ACH), domestic wire transfer, affiliate bank post-acquisition conversions and consolidations, bank operation centralizations, and payment system risk. His areas of expertise include education, ACH processing and compliance, and AML/BSA. 1 “Elder Financial Exploitation Awareness,” nacha.org, 2025. 2 “Advisory on Elder Financial Exploitation,” fincen.gov, June 15, 2022. 3 “Financial Trend Analysis,” fincen.gov, April 2024. 4 “U.S. and World Population Clock,” census.gov, June 18, 2026. 5 “Elder Financial Exploitation Awareness,” nacha.org, 2024. 6 “2026 National Money Laundering Risk Assessment,” home.treasury.gov, March 2026. 7 “FTC Issues Annual Report to Congress on Agency’s Actions to Protect Older Adults,” ftc.gov, December 1, 2025. 8 “Reported losses to scams on social media eight times higher than in 2020,” ftc.gov, April 27, 2026. 9 “Federal Bureau of Investigation Internet Crime Report 2025,” ic3.gov, 2025. 10 “SAR Stats,” fincen.gov, updated May 31, 2026. Colorado Banker 6
B:Side Capital and B:Side Fund, a non-profit small business lender and Certified Development Financial Institution (CDFI), announced the launch of its AI-powered financial intelligence platform designed exclusively for small business owners. The platform connects directly to users’ bank accounts to deliver real-time visibility into cash flow, automated anomaly detection and forward-looking forecasts — all in a single, unified dashboard. Small business owners have long faced a gap between the financial data they have and the insights they need to act on it. B:Side Assist closes that gap by combining bank account synchronization, AI-driven analysis and expert human support into one platform that works as an always-on financial partner. “Most small business owners don’t find out there’s a problem until it’s already a problem,” said B:Side CEO Chris Myers. “We built B:Side Assist to surface what matters before it becomes critical, so owners can spend less time digging through numbers and more time building their business.” What B:Side Assist offers: • Real-Time Dashboards: A live view of spending, budgeting and financial performance, updated as transactions happen. • AI-Powered Insights: Automatic detection of anomalies, spending patterns and savings opportunities, surfaced without any manual analysis required. • Instant Forecasting: Cash flow projections and scenario modeling that let owners plan ahead with confidence, not guesswork. • Unified Platform: Personal and business finances tracked together in one place, in real time. • Expert Support: Access to a network of financial professionals for a human perspective when it counts. • Beyond Finances: Guidance on leadership, operation and entrepreneurial strategy to support the full picture of running a business. B:Side Assist Launches AI-Powered Financial Platform for Small Business Owners The platform is designed to automate routine financial tasks so owners can stay focused on growth. From identifying where money is quietly leaking to modeling what happens if revenue dips next quarter, B:Side Assist turns raw financial data into decisions. B:Side Assist is available now. To learn more or request a demo, contact us at hello@bside.org. B:Side Capital is a Certified Development Company (CDC) and Lender Service Provider (LSP) dedicated to supporting lending partners across Colorado, New Mexico, Utah and Arizona through the Small Business Administration (SBA) 504 loan program and 7(a) loan program nationwide. We are committed to expanding access to responsible, affordable capital for small businesses while serving as a trusted resource for both banks and entrepreneurs. In partnership with our sister organization, B:Side Fund, a Certified Development Financial Institution (CDFI), we focus on reaching underserved markets, driving economic growth and job creation through SBA and direct lending solutions. Our programs enable lenders to meet financing needs that may fall outside conventional credit policies. Since 1990, B:Side Capital has funded more than 5,500 small business loans, supporting over 45,000 jobs and generating $6.5 billion in economic impact. By B:Side 7 Colorado Banker
250 Years of Betting on the American Dream By MeKelee LaFoy, Business Development Representative, CP Insurance Associates The United States of America just celebrated its 250th anniversary this summer, allowing us an opportunity to reflect on one of the nation’s most enduring success stories: the belief that ordinary people, given access to opportunity, can achieve extraordinary things. That belief has fueled the American Dream. It has inspired entrepreneurs to start businesses, families to buy homes, farmers to invest in their land and communities to build schools, hospitals and local industries. While countless individuals have contributed to this story, few institutions have played a more consistent role in turning aspiration into achievement than America’s banks. At its core, banking is an act of optimism. Every loan represents confidence in the future. Every mortgage reflects faith in a family’s ability to build stability and wealth. Every small-business loan invests in the belief that an entrepreneur’s vision can become a thriving enterprise. For generations, bankers have accepted calculated risks in pursuit of greater rewards, not only for their institutions but also for the customers and communities they serve. That commitment has helped fuel America’s economic growth for two and a half centuries. A Financial System Built on Opportunity One of the defining strengths of the American financial system is its ability to expand access to capital. Through a diverse network of financial institutions, Americans from all walks of life have opportunities to pursue goals that might otherwise remain out of reach. A first-time homebuyer secures a mortgage. A startup founder obtains financing to launch a new venture. A family-owned manufacturer invests in equipment to expand production. A farmer purchases land or modernizes operations for the next generation. Colorado Banker 8
Individually, these transactions may seem routine. Collectively, they represent something extraordinary: a financial system that helps transform ambition into achievement. The American economy has been defined by the opportunity to create wealth through hard work, innovation and responsible access to capital. Banks serve as the bridge between dreams and reality. Community Banks: Investing in Their Neighbors No institutions embody this mission more directly than community banks. For generations, community banks have served as economic anchors in towns and cities across America. Their leaders know the local businesses on Main Street, understand regional industries and appreciate the unique needs of the communities they serve. This local knowledge creates value that extends far beyond financial statements. When a community bank finances a new business, the benefits often ripple throughout the local economy. Jobs are created. Suppliers gain customers. Families experience greater financial stability. Tax revenues help support schools, infrastructure and public services. In many communities, the local bank is a trusted partner in economic development. The success of community banks and their communities is deeply connected. When local businesses grow, banks grow. When families prosper, communities become stronger. This relationship reflects a uniquely American principle: Prosperity is strongest when opportunity is widely available. Managing Risk While Building Opportunity Of course, banking has never been without risk. Every extension of credit involves uncertainty. Economic conditions change, markets fluctuate and unexpected events occur. The future is never guaranteed. Yet successful banking has never been about avoiding risk altogether. It has been about managing risk responsibly while continuing to support economic growth. Sound underwriting, diversified portfolios, strong capital positions and disciplined risk-management practices are essential to a healthy banking system. Equally important are the safeguards that protect both financial institutions and the collateral that supports their lending activities. When banks extend credit, they often rely on collateral such as homes, vehicles, commercial properties, equipment and agricultural assets. Insurance coverage helps protect the value of that collateral from unforeseen losses, preserving financial stability for both borrowers and lenders. When disaster strikes, insurance can help families rebuild, businesses recover and loans remain secure. Banks themselves also depend on comprehensive insurance protections as part of a broader risk management strategy. Specialized coverages help institutions remain resilient in an increasingly complex risk environment. These protections do more than safeguard balance sheets. They help ensure that banks can continue to serve customers and support local economies amid changing conditions. Risk management and community development are not competing priorities. They are complementary goals. Responsible lending, supported by strong risk controls and appropriate insurance coverage, creates sustainable growth that benefits borrowers, banks and communities alike. The Next 250 Years As America enters its next chapter, the opportunities ahead remain immense. New technologies are transforming industries. Entrepreneurs continue to develop innovative products and services. Communities are finding new ways to grow and compete. Families continue to pursue the timeless goals of homeownership, education and financial security. The tools may evolve, but the mission endures: connecting capital with opportunity. Helping individuals turn plans into reality. Supporting businesses that create jobs and strengthen local economies. Investing in communities that will shape the future. For 250 years, bankers have made a calculated wager on the potential of the American people. Guided by prudent risk management and a commitment to serving their communities, they have provided the financial foundation upon which countless dreams have been built. It has been a remarkably successful bet. As we celebrate America’s 250th birthday, we can also celebrate the institutions that have helped make the American Dream possible. For generations, banks — and especially community banks — have invested in the people, businesses and communities that drive our nation’s prosperity. That investment continues today. And if history is any guide, it will continue for the next 250 years and beyond. 9 Colorado Banker
Driving Community Prosperity With Reciprocal Deposits By Joe Hooker, Chief Sales Officer, IntraFi Community banks, which make up at least 90% of all banks nationwide, are the backbone of American small businesses.1 An ICBA report found that roughly 60% of small business loans and over 80% of agricultural loans come from community banks.2 But community banks face steep challenges, including net interest margin compression, compliance and cybersecurity burdens, and new, often digital-only, competitors. In fact, 97% of respondents to IntraFi’s Q1 2026 survey of bank executives say they expect deposit competition to remain at current levels or increase over the next year. To stay competitive and continue providing the vital banking services their communities depend on, community banks need every advantage available to attract and retain high-value relationships. Reciprocal deposits are an essential tool that allows community banks to support local deposit and lending needs, enabling banks to offer large depositors access to millions in FDIC insurance while keeping funds local to lend in the community. Reciprocal Deposits Typically Have a High Reinvestment Rate Reciprocal deposits are deposits that a bank receives through a deposit placement network in return for placing a matching amount of deposits at other network banks. Importantly, the institution placing the deposit maintains its relationship with the depositor, allowing safety-conscious customers to obtain FDIC insurance on large balances through multiple network banks while maintaining a single bank relationship. Colorado Banker 10
At the same time, a bank that participates in a deposit placement network can attract and retain more deposits from local customers. Historically, reciprocal deposits have been “sticky,” with high reinvestment rates and low likelihood of liquidation in any given month, even as total accounts and balances steadily increase. After the high-profile bank failures of 2023, reciprocal deposit balances at banks with between $1 billion and $100 billion in assets increased by 20% and remained elevated across 2024. A recent research paper finds that higher levels of insured deposits were associated with reduced deposit outflows during the 2023 regional banking crisis. The study also reports that banks with higher insured deposit levels paid lower deposit interest rates, grew larger and increased their local deposit market share over time.3 In fact, the growth rate for reciprocal deposit balances across banks of all sizes was 131% from 2022 to 2023. Reciprocal balances grew an additional 15% across 2024.4 Reciprocal Deposits Compare Well to Other Bank Funding Choices In addition to helping banks grow wallet share among local customers, reciprocal deposits can offer several advantages over other bank funding options. • Reduced Collateralization Needs: Reciprocal deposits can reduce or eliminate collateralization requirements, freeing up pledged collateral and reducing the burdens associated with tracking collateral. • Alternative to Wholesale Funding: Unlike many forms of wholesale funding, most reciprocal deposits can qualify as non-brokered deposits under the law. • Superior to Listing Service Deposits: When compared to listing service deposits, reciprocal deposits can provide a more stable, relationship-based source of funding that is typically lower cost and less rate sensitive. The Value of Balance Sheet Flexibility Overall, using deposit placement networks provides meaningful flexibility for balance sheet management. Banks can keep funds on the balance sheet as reciprocal deposits or, alternatively, sell funds into their deposit network and earn fee income (while keeping the customer relationship).5 The ability to move funds on and off the balance sheet on demand can significantly reduce the need for community banks to turn away a valued depositor because of the deposit insurance limits, deepening relationships and giving banks greater control to meet their liquidity needs. Reciprocal deposits also provide a stable funding source to support lending while offering the agility needed to respond rapidly to changing market conditions. Using a reciprocal deposit network, banks can grow relationships and deposits from a local customer base without the added costs or tracking burdens associated with ongoing collateralization requirements, while still lending these funds locally. To learn more about how your institution can use reciprocal deposits to expand its lending capacity and strengthen its local community, visit intrafi.com/grow-reciprocal-deposits. Deposit placement through ICS 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 “U.S. Community Banks: Holding up Well with Strong Asset Quality Despite CRE Exposures,” Morningstar, accessed Jan. 12, 2026, https://dbrs.morningstar.com/research/440556. 2 “Revealed: The Impact of Credit Union Acquisitions,” ICBA, last modified Dec. 1, 2025, https://www.icba.org/w/revealed-the-impact-of-credit-union-acquisitions. 3 Edward T. Kim, Shohini Kundu, and Amiyatosh Purnanandam, “The Economics of Market-Based Deposit Insurance,” published September 2024, https://www.fdic.gov/system/files/2024-09/kim-edward-paper-091124.pdf. 4 S&P Call Report Data 5 With a depositor's consent, the bank may choose to receive fee income instead of deposits from other participating institutions. Under these circumstances, deposited funds would not be available for local lending. 11 Colorado Banker
While our name has changed under new ownership, the heart of our company remains the same — including the reliable, friendly team you’ve always worked with. Our goal is to be a trusted partner for trade and professional associations, strengthening membership and connecting member businesses with their future customers. We look forward to what’s to come! mbr-connect.com (801) 676-9722 hello@mbr-connect.com New name. Same people. Renewed commitment. We’re excited to announce that is now
CBA Centerpoint Kellie Ehrhard Greeley Market President FirsTier Bank What is the most rewarding aspect of your job? For me, it’s the growth I’ve seen in the people I lead. Knowing I played a role, however small, in them becoming more confident and effective is the most rewarding part of my career. What is the most important thing you’ve learned from a career in banking? Always be open to change and never burn bridges, as you never know who your next boss will be ― or who may be buying you out! What makes your bank unique? FirsTier Bank is a community bank with locations throughout Colorado, Nebraska and Wyoming. Our roots date back to 1955, when a small group of bankers and local businessmen opened Kimball County Bank with a vision to provide quality services that would help their local community grow and prosper. Today, we continue to be community builders — committed to the communities we serve and to providing the highest level of customer service, strength and stability to our business and personal banking customers. When you were a child, what did you want to be when you grew up? I’ve loved space since I was a small child. I wanted to be an astronaut badly! I was the president of the astronomy club and the rocket club. As I got older, I joined the Civil Air Patrol, hoping to progress to the Air Force. Unfortunately, high school changed things and being social/boys became more important. What do you geek out about? I have a bird feeder that has a camera, which I love! I have recorded 23 bird species so far. I am obsessed, and I’m hoping to attract a cardinal. Flint Mulder Regional President U.S. Bank How did you get started in the banking industry? Like many of my peers, I would classify myself as an accidental banker. Shortly after high school, I joined the U.S. Army, where I served as a Russian translator for a military intelligence unit in Fairbanks, Alaska. Upon receiving an honorable discharge, I earned a journalism degree at the University of Oregon and subsequently stumbled upon an opportunity to work as a mortgage banker. This turned into a 28-year career with U.S. Bank, where I’ve had the privilege of leading retail, business and commercial banking teams across the Western U.S. What do you like to do to give back to the community? As a veteran, I feel that it is my duty to give back to those who have sacrificed so much to protect our way of life. This is why I am an executive sponsor for Proud to Serve, U.S. Bank’s military business resource group dedicated to supporting active-duty military members, reservists, veterans and their families in the communities that we serve. I’m proud to work for a company that is such a strong supporter of service. U.S. Bank has appeared on the Military Times’ Best for Vets: Employers list (2010-2023) and Veteran Magazine’s Top Veteran-Friendly Companies list (2015-2022). And through various programs over the years, we have partnered with service organizations to donate mortgage-free homes to wounded veterans, repair veteran homes and provide payment-free vehicles to veterans in need. What are you most proud of in your professional life? At U.S. Bank, our purpose is to “invest our hearts and minds to power human potential.” It’s coincidental, but the bank’s corporate “purpose” has been a lifelong passion of mine. When it comes to my professional life, this ties to what I’m most proud of: the individuals with whom I have worked over the years at U.S. Bank, who have done the hard work to become dynamic, successful leaders and bankers. Tell us something about yourself that most people don’t know. One thing that often surprises people is that President Abraham Lincoln is a distant cousin. His grandfather was one of my great-grandfathers. 13 Colorado Banker
Why Overdraft Should Be Managed as a Service Line By Cheryl Lawson, Executive Vice President of Compliance Review, ADVANTAGE Overdraft has become one of the most closely watched areas of financial services. Regulatory scrutiny, consumer expectations, fee sensitivity and reputational risk have all intensified the conversation. The greater concern is when programs are inconsistently managed, poorly communicated or treated only as a source of non-interest income. When overdraft is viewed solely as a fee line, it can create confusion for customers, operational challenges for staff and unnecessary exposure for the bank. A more effective approach begins with a simple shift in perspective: Overdraft should be managed as a service line. That distinction matters. Managing overdraft as a service line means treating it as a customer experience, operational process and compliance responsibility — not simply a fee event. A Service Line Approach Changes How Overdraft Is Communicated For many consumers, overdraft protection serves as a financial safety net during periods when income and expenses do not perfectly align. A paycheck may post a day later than expected. An automatic payment may clear before a deposit is available. A small shortfall can quickly become a larger issue if an important transaction is declined. When overdraft is communicated clearly, customers are better equipped to understand how the service works, when it may apply, what choices they have and what costs may be involved. A responsible, service-focused approach emphasizes transparency, education and consistency — not just compliance language. Clearer Communication Improves the Customer Experience If an overdraft program is reactive, confusing or inconsistently applied, it can damage trust. But when a program is thoughtfully structured, clearly explained and regularly Colorado Banker 14
• Is it monitored? • Is it aligned with customer needs? • Is it supported by training, reporting and ongoing oversight? When the answers are yes, overdraft can be more than a fee-based product. It can be a service that supports customers, strengthens operational discipline and helps banks navigate regulator expectations with greater confidence. Overdraft does not have to be a source of confusion or concern. When managed responsibly, it can be a structured service that customers value and use when needed. The opportunity for community banks is to move beyond outdated assumptions and manage overdraft with the same care, structure and focus they bring to every other important customer service. Contact us at advantage-fi.com/contact-us to explore how a service-focused approach can help your bank manage overdrafts with greater clarity, consistency and confidence. Cheryl Lawson is executive vice president of compliance review at ADVANTAGE. She helps community financial institutions navigate overdraft compliance, strengthen program oversight, and support responsible practices that align with regulatory expectations and consumer needs. monitored, it can support customers while helping the bank maintain responsible practices. That includes looking at questions such as: • How are customers informed about their options? • Are staff trained to explain the program clearly and confidently? • Are overdraft limits and practices aligned with the bank’s risk tolerance and customer needs? • Are reports reviewed regularly to identify trends, exceptions or areas of concern? • Are communications written in a way that customers can actually understand? These are not just compliance questions; they are service questions that influence whether overdraft is experienced as a helpful option or a source of frustration. Ongoing Oversight Supports Stronger Compliance Regulators continue to focus on fairness, transparency, consumer harm and whether financial institutions can demonstrate that their practices align with today’s program expectations. That makes documentation, training, monitoring and consistency more important than ever. When overdraft is managed as a service, compliance becomes part of the operating model — not a last-minute reaction to examiner feedback or regulatory pressure. It’s consistent execution across the organization that demonstrates a clear commitment to responsible practices. Responsible Design Strengthens Long-Term Performance A well-managed overdraft program can help protect non-interest income, support customer relationships, reduce confusion, improve staff confidence and strengthen the institution’s ability to respond to regulatory expectations. The programs that perform well are not necessarily the most aggressive. They are the ones built with structure, oversight, communication and customer experience in mind. That is where responsible design becomes a competitive advantage. The Conversation Around Overdraft Is Changing Overdraft remains a focus for regulators, consumer advocates and financial institutions, but the conversation does not have to be reduced to a binary question of whether overdraft is good or bad. The more useful question is whether the program is designed and managed responsibly. • Is it clear? • Is it consistent? 15 Colorado Banker
AI Deployment in Financial Institutions Why Some Banks Succeed A growing number of financial institutions are exploring the integration of AI into their workflows with uneven outcomes. A widely cited 2025 MIT study found that roughly 95% of corporate AI pilots fail to deliver a measurable financial return.1 For boards and executives who have watched budgets flow into chatbots and copilots with little to show for it, the figure invites an uncomfortable question: Is AI a dud? The evidence suggests the opposite. The high failure rates of these initiatives reflect how institutions deploy AI, not whether the underlying technology works. The AI capability curve is steepening, and the gap between institutions seeing real returns and those stuck in perpetual pilots comes down to a handful of choices that have little to do with which model a vendor sells. Does AI Actually Work? When considering the efficacy of an AI pilot, it helps to separate two things that are often conflated: the maturity of the technology versus the maturity of its deployment. On the technology side, progress is accelerating. Independent benchmarking by METR, which measures the length of tasks AI systems can complete reliably, shows frontier models advancing from short, novelty-grade outputs a few years ago to sustained, day-long task execution today — work that, in human terms, runs beyond a full nine-to-five.2 On the deployment side, the picture is messier, and that is where the disappointment often stems from. Industry analysts place agentic AI somewhere on the early downslope of the classic hype cycle — past the peak of inflated expectations and working through the trough of disillusionment before the plateau of productivity.3 Historically, that journey takes two to five years. While adoption appears to be moving faster than in prior technology waves, being early nonetheless offers no protection against poorly orchestrated AI deployments. Why Outcomes Vary: Purpose and Conviction Institutions that have experienced positive outcomes following AI deployments often share two traits. First, they deploy with purpose. A useful illustration or measure of this would be whether an institution approaches the deployment goal with concrete KPIs. For instance, “increase NPS by three points” or “cut delinquency-management costs by six percent.” Those numbers carry a concrete purpose. On the other hand, launching “an AI chatbot for our website” lacks that directionality and clear goal. The data shows that roughly 78% of companies use AI, with typical impacts of below 10% in cost savings and under 5% in revenue uplift, and that only about 1% of U.S. firms have truly scaled AI across the enterprise.4 The differentiator is workflow redesign. An estimated 90% of the value captured by successful firms comes from reshaping and inventing workflows, not from sprinkling AI on top of legacy processes.5 High performers embed AI where decisions are actually made, across entire processes rather than via isolated pilots, and move deliberately from “humans using tools” to AI-supported workflows that humans orchestrate. Those same firms are roughly five times more likely to do strategic workforce planning for AI. Second, they deploy with conviction. Successful AI is run as a CEO- and board-sponsored, multiyear program with a funded roadmap rather than via a series of hedged experiments. High performers are about three times as likely as their peers to expect transformative business change While Others Don’t By Michael Goh, Cofounder and CEO, Krew Colorado Banker 16
from AI within three years, and roughly one-third devote more than 20% of their digital budget to it while systematically tracking KPIs.6 For an institution considering AI implementation, these three practices can be most useful in driving meaningful impact down the line: 1. Set a baseline metric, a target and a named owner for each AI deployment from day one. 2. Redesign the underlying workflow end-to-end rather than automating a single step. For every process, label each task explicitly as AI-led, human-in-the-loop or human-only, with documented escalation rules. 3. Pair that with a multiyear value thesis, for instance, “+3 points of NPS from AI in loan servicing,” and stage gates that define what evidence is required to move from pilot to scale. What ‘AI’ Actually Means Today Part of the confusion on this topic is linguistic. “AI” is more than just large language models; large language models are only one of roughly five families of machine-learning models, each suited for different jobs. Tree-based models work like auto-generated if-this-then-that rules and excel at fraud detection and delinquency-risk prediction. Linear and logistic models capture straightforward relationships and support risk scoring and segmentation. Neural networks recognize complex patterns and underpin default prediction and fraud detection. Unsupervised models find hidden structure in data, grouping borrowers by behavior or financial stress without being told the right answer. Large language models, the technology behind tools such as ChatGPT, predict the most likely next word in a sequence and, on their own, have no goals or understanding. The more consequential shift for financial institutions is the arrival of AI agents. An agent is best understood as a workflow orchestrator that can think, decide and act, not merely respond. Agents break goals into steps, call systems, and enterprise data and adapt as they go. In servicing and collections, this translates into concrete roles: QA agents who review interactions against custom scorecards, loan-servicing agents who handle payment plans and hardship options, delinquency-management agents who tailor outreach, and back-office agents who process documents and complete routine tasks. The New Risk Categories Because agents take action across multiple steps within a process rather than simply generate text, they introduce risks that traditional model governance was not designed to catch. The most counterintuitive is compounding error. A 98% per-step success rate sounds excellent until five steps are chained together, at which point overall accuracy falls to roughly 90%. That means one in ten workflows would fail. In a regulated collections process, that is not an acceptable margin. Three further failure modes deserve board-level attention. Agents can hallucinate or misrepresent policy, inventing non-compliant financial advice, referencing competitors the institution does not endorse, or making insensitive assumptions about a borrower’s circumstances. They can miss edge cases, failing to recognize manipulative language or legal traps; a borrower who says “I have no money to pay you” may be invoking a script that makes further contact a potential FDCPA or RFDCPA violation. And they can be manipulated directly, through prompt-injection attempts that try to hijack the agent into saying something off-brand or non-compliant. Mitigations for these cases should be non-negotiable. Hard-coded guardrails and specially trained oversight models that check other models’ work can catch hijacking attempts and block poor responses before they reach a borrower. Rigorous evaluation in simulated environments also quantifies error rates across categories such as jailbreaking, hallucinations, content moderation, competitor references and policy-sensitive requests, such as bankruptcy or cease-and-desist notices. Finally, human-in-the-loop review remains essential for high-uncertainty cases. These measures build confidence in risk management by grounding error rates in concrete data and expressing them as a number that can be insured against. What Regulators Expect Supervisory expectations from the CFPB, FDIC, OCC and FFIEC are converging around four themes, and institutions should map any AI deployment against all of them: • Explainability: The ability to explain, in plain language, how AI is used in a product or process; specific and accurate reasons for credit denials and other adverse actions, with no “black box” excuses; and documented model purpose, assumptions and limitations. • Borrower Impact: Demonstrated testing for disparate impact and unfair bias across protected classes; ongoing monitoring of approval rates, pricing and servicing outcomes; and clear disclosures, opt-outs where applicable and easy access to a human review or complaint path. • Model Governance: Treating AI as “models” under SR 11-7-style guidance, with an inventory, named owners and use-case documentation; independent validation before go-live and regular back-testing for drift and performance; and board and senior-management oversight. • Data Privacy: Lawful data use under FCRA, GLBA and UDAAP, with limits on surveillance and non-traditional data; strong vendor controls, including rights to audit, explain, remediate and shut down AI systems; and cybersecurity, access control and logging around training data, prompts and outputs. Where the Opportunities Are When deployed with clarity and discipline, AI can drive material gains across an institution. Use cases most beneficial for banks 17 Colorado Banker
include customer service, where omnichannel agents deliver consistent, compliant responses around the clock; fraud and risk monitoring, with real-time anomaly detection and lighter manual-review loads; loan servicing, with instant, accurate answers and automated follow-ups that lower handle times; delinquency management, where outreach adapts to borrower intent and personalized payment plans improve cure rates; and back-office automation, covering data entry, document processing and QA scoring. In continuous QA, every voice or chat interaction is scored by an evaluation agent against criteria tied to regulatory and internal policy, flagging non-compliance, surfacing trends on team and topic dashboards, and routing feedback to supervisors. In automated servicing, an agent captures caller intent in real time, retrieves the next-best response from approved knowledge bases and servicing guidelines, and writes updated information, such as payment status, promises-to-pay and address changes, back to core systems so the next interaction starts with the current context. In both cases, the value comes from redesigning the whole loop, not affixing a chatbot onto the front of it. The Board’s Checklist AI is neither a silver bullet nor a dud; it is a capability that rewards purposeful, well-governed deployment and punishes the opposite. Before approving an AI program, boards should confirm that management has four things in place: a documented AI strategy tied explicitly to borrower value and operational efficiency; a governance framework aligned with regulatory expectations; robust vendor controls, testing protocols and model-lifecycle oversight; and clear policies for privacy, fairness, explainability and incident escalation. The institutions that get this right will not be the ones that adopt AI earliest or spend the most. They will be the ones who deploy it with clear objectives, redesigned workflows and humans firmly in the loop. Michael Goh is the cofounder and CEO of Krew. Prior to Krew, he led speech benchmarking at Artificial Analysis, an Andrew Ng-backed company, where he worked alongside OpenAI and Amazon to conduct performance and quality evaluations for their multimodal LLMs, focusing on speech inputs. Michael earned his MS in computer science from the University of Chicago, where he was a Global Fellow, and his BA in economics and management from the University of Oxford, where he was a Fung Scholar. 1 MIT, “State of AI in Business 2025” (Challapally et al., 2025). 2 METR, “Measuring AI Ability to Complete Long Tasks” (2025). 3 Gartner, “Hype Cycle for Artificial Intelligence” (July 2025). 4 The Wall Street Journal, “Companies Are Struggling to Drive a Return on AI. It Doesn’t Have to Be That Way” (2025). 5 Boston Consulting Group, “The Widening AI Value Gap” (2025). 6 McKinsey & Company, “The State of AI in 2025: Agents, Innovation and Transformation” (2025). YOUR DEBT PORTFOLIO MAY NOT BE KEPT IN HERE, BUT IT’S STILL AN ASSET They may not be currency, but debt portfolios which include credit card, auto deficiency, overdraft, judgements or commercial and consumer loans definitely have value. We’ll buy your debt portfolio from the last four years, with minimum sizes of $100k on at least ten accounts and no maximums. We’ll even walk you through the sales process to help with compliance and data integrity. To offload your debt portfolio, contact Craig Geisler at cgeisler@cherrywoodenterprises.com or (321) 247-5066. Colorado Banker 18
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