NOVEMBER/DECEMBER 2025 A PUBLICATION OF THE INDEPENDENT COMMUNITY BANKERS OF COLORADO BUILDING ON THE PAST, BANKING ON THE FUTURE. 52nd Annual Convention Recap Camp ICBC — Where Colorado Community Banks Thrive
©2025 The Independent Community Bankers of Colorado (ICBC) | The newsLINK Group LLC. All rights reserved. Independent Report is published six times per year by The newsLINK Group LLC for ICBC 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 ICBC, 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. Independent Report is a collective work, and as such, some articles are submitted by authors who are independent of ICBC. While a first-print policy is encouraged, in cases where this is not possible, every effort has been made to comply with any known reprint guidelines or restrictions. Content may not be reproduced or reprinted without prior written permission. For further information, please contact the publisher at (855) 747-4003. 6732 W. Coal Mine Ave., #640 • Littleton, CO 80123 • (303) 832-2000 2025-2026 OFFICERS ICBC CHAIRMAN Mike Hurst President Del Norte Bank ICBC PRESIDENT Joe Martinez President & CLO San Luis Valley Federal Bank ICBC PRESIDENT-ELECT Robert Holt Senior Credit Officer & SVP North Valley Bank ICBC ICBA STATE DIRECTOR PJ Wharton President & CEO Yampa Valley Bank ICBC STAFF EXECUTIVE DIRECTOR Mike Van Norstrand mvannorstrand@icbcolo.org ADMINISTRATION DIRECTOR/ TREASURER Maelynn Lewis mlewis@icbcolo.org ADMINISTRATIVE SUPPORT MANAGER Lori Arellano larellano@icbcolo.org LEGAL COUNSEL Christian Otteson Partner Otteson Shapiro LLP LOBBYIST Mary Marchun Founding Partner The Capstone Group 2025-2026 DISTRICT DIRECTORS DISTRICT A Kent Jones, President & CEO, Flatirons Bank Jamie Santistevan, COO, Native American Bank Mark Sheeley, President & CEO, RNB State Bank/Front Range State Bank Jeff Walker, Senior Vice President & CCO, Redstone Bank DISTRICT B Mark Brase, President, Points West Community Bank Tim Croissant, Market President, Bank of Colorado Travis Goeglein, Senior Vice President, First FarmBank Scott Applegate, President & CEO, Bank of Estes Park DISTRICT C Ben Johnson, President, First National Bank Colorado Miles McClure, CEO, Rocky Mountain Bank & Trust Peter Page, Executive Vice President & COO, Frontier Bank Kathryn Perry, Senior Vice President, Park State Bank & Trust DISTRICT D Dan Ebert, Vice President, Evergreen National Bank John Stelzriede, Market President — Colorado River Region, Alpine Bank Niki Stotler, President & CEO, High Country Bank Chad Zummach, Executive Vice President, Gunnison Bank & Trust ICBC ADVISORY BOARD MEMBERS Eric Budreau Partner Eide Bailly Jim Hall Managing Director Bond & Specialty Insurance — Financial Institutions, Travelers Bill Mitchell President & CEO Bankers’ Bank of the West Christian Otteson Partner Otteson Shapiro LLP 2 | INDEPENDENT REPORT
22 CONTENTS 8 16 CONNECT Email us mlewis@icbcolo.org Like us on Facebook ICBColo Connect with us ICBColo Follow us on X ICBColo Give us a call (303) 832-2000 Follow us on Instagram ICBColo 2025 PUB. 4 ISSUE 6 4 Support the ICBC’s Associate Members! 5 ICBC Preferred Providers FLOURISH 6 Rising Concerns Over National Bank Trust Charters By Rebeca Romero Rainey, President & CEO, ICBA FROM THE TOP 7 Digital Banking for the Modern Age By Jack E. Hopkins, Chairman, ICBA 8 52nd Annual Convention Recap Camp ICBC — Where Colorado Community Banks Thrive ASSOCIATE GOLD MEMBER SPOTLIGHT 12 Richey May A Conversation with Michael Nouguier and Brent Murray 14 ATM Jackpotting Trends in the Mountain West A Growing Threat to Community Banks — What You Can Do To Mitigate the Risk By Wade Zirkle, President & CEO, BluePoint ATM Solutions, ICBC Preferred Provider and ICBC Associate Member 16 Making a List, Checking It Twice Year-End Is Approaching. Here Are Some Seasonal Reminders. By Jim Reber, President & CEO, ICBA Securities, ICBC Preferred Provider and ICBC Associate Member 18 Strengthening Franchise Value Why Community Banks Are Growing Their Use of Reciprocal Deposits By Joseph Hooker, Chief Sales Officer, IntraFi, ICBC Associate Member 20 ICBA LIVE San Diego March 6-9, 2026 21 AI — It’s Not Just for Drafting Your Holiday Updates Why Every Colorado Bank Needs an AI Policy Now By Jenny Small, Partner, Otteson Shapiro, ICBC Associate Member 22 Digital Transformation in Banking The Role of Cybersecurity in Modern Banking By Chad Knutson, CEO, SBS CyberSecurity, ICBC Preferred Provider and ICBC Associate Member INDEPENDENT REPORT | 3
SUPPORT THE ICBC’S ASSOCIATE MEMBERS! ACCOUNTING | COMPLIANCE EideBaillyLLP. . . . . . . . . . . . . . . . . . . . . . . . . .(303)770‑5700 Fortner Bayens PC . . . . . . . . . . . . . . . ........ (303) 296‑6033 Forvis Mazars . . . . . . . . . . . . . . . . ......... (303) 861‑4545 Moss Adams LLP now Baker Tilly . . . . . . . . . . . . . . (503) 471‑1277 Plante Moran** . . . . . . . . . . . . . . . . ........ (303) 740‑9400 ADVERTISING | EQUIPMENT | PRINTING | SUPPLIES Kristopher James Company . . . . . . . . . . . . . . . . . (800) 274‑9212 Spry.. .. .. .. .. .. .. .. .. .. ............ (303) 323‑4341 CAREER ADVANCEMENT Graduate School of Banking at Colorado . . . . . . . . (800) 272‑5138 CONSULTING | HUMAN RESOURCES AND MANAGEMENT | MARKETING | STRATEGIC PLANNING BankStrategiesLLC . . . . . . . . . . . . . . . . . . . . . . (303)291‑3700 (A Bankers’ Bank of the West Bancorp Inc. Subsidiary) Expert Business Development . . . . . . . . . . ..... (610) 771‑2121 Hopkins Leadership . . . . . . . . . . . . . . . . . . . . . . (225) 773-4528 *ICBA CRA Solutions .. .. .. .. .. .. ........ (877) 232-0859 *ICI Consulting Inc. .. .. .. .. .. .. .......... (316) 201‑8590 TheJamesPaulGroup . . . . . . . . . . . . . . . . . . . . (877)584‑6468 MJCPartners . . . . . . . . . . . . . . . . . ......... (213) 278‑0429 The NaviTrust Group . . . . . . . . . . . . . . ....... (801) 438-1842 Piper Sandler & Co. . . . . . . . . . . . . . . ........ (415) 978‑5057 *S&P Global .. .. .. .. .. .. .. .. ........... (434) 951‑6948 CORRESPONDENT BANKING SERVICE *Bankers’ Bank of the West .. .. .. .. .. ....... (303) 291‑3700 BellBank. . . . . . . . . . . . . . . . . . ........... (701) 371‑3355 Citizens Bank Farmington . . . . . . . . . . . . ...... (505) 599‑0100 INTRUSTBank . . . . . . . . . . . . . . . . ......... (800) 732‑5120 PCBB.. .. .. .. .. .. .. .. .. .. ........... (888) 399‑1930 TIB — The Independent BankersBank . . . . . . . . . . . (972) 650‑6000 CYBERSECURITY | IT CONSULTING AND SERVICES | SECURITY Alogent..............................(719)583‑8004 ArcticWolf............................(888)272-8429 Botdoc.. .. .. .. .. .. .. .. .. ............ (719) 960-4475 CivITas Bank Solutions . . . . . . . . . . . . . ....... (303) 291‑3700 (A Bankers’ Bank of the West Bancorp Inc. Subsidiary) Cook Solutions Group . . . . . . . . . . . . . ....... (503) 260‑8562 Federal Protection Inc. . . . . . . . . . . . . . ....... (800) 299‑5400 FileInvite. . . . . . . . . . . . . . . . . . ........... (719) 771-3586 M.R.Solutions. . . . . . . . . . . . . . . . . . . . . . . . . .(303)296-3328 Richey May Cyber*** . . . . . . . . . . . . . . ....... (303) 721-6131 *SBS CyberSecurity .. .. .. .. .. .. .......... (785) 594‑0503 DATA PROCESSING | EFT | ATM | CARD PROCESSING | MERCHANT SERVICES *Bankers’ Bank of the West .. .. .. .. .. ....... (303) 291‑3700 *BluePoint ATM Solutions LLC .. .. .. .. ....... (540) 335‑2848 Computer Services Inc. . . . . . . . . . . . . . . . . . . . . (970) 212‑7104 DCI.................................(620)694-6800 *IBT Apps . . . . . . . . . . . . . . . . . . . . . . . . . . . . (512) 606‑1100 *ICBA Bancard / TCM Bank .. .. .. .. .. ....... (800) 242‑4770 Jack Henry & Associates . . . . . . . . . . . . ....... (417) 235‑6652 SHAZAM.. .. .. .. .. .. .. .. .. ........... (515) 288‑2828 VisaInc.. . . . . . . . . . . . . . . . . . ........... (415) 238‑3682 INSURANCE | BENEFIT SERVICES Bank Compensation Consulting . . . . . . . . . . . . . . (303) 482‑1844 First Insurance Services Inc. . . . . . . . . . . . ...... (719) 456‑2303 *ICBA Reinsurance . . . . . . . . . . . . . . . . . . . . . . (888) 790‑6615 *Travelers .. .. .. .. .. .. .. .. ............ (720) 200‑8416 INVESTMENTS | FUNDING AND LENDING PARTNERS B:SideCapital. . . . . . . . . . . . . . . . . . . . . . . . . .(303)657‑0010 TheBakerGroup. . . . . . . . . . . . . . . . . . . . . . . . (405)415‑7200 BancAlliance . . . . . . . . . . . . . . . . . ......... (301) 232‑5423 *BHG Financial Institutional Network*** .. .. .... (954) 263‑6399 Citizens Bank Farmington . . . . . . . . . . . . ...... (505) 599‑0145 Colorado Enterprise Fund . . . . . . . . . . . . ...... (303) 860‑0242 Colorado Housing and Finance Authority . . . . . . . . (303) 297‑7329 D.A.Davidson..........................(303)764‑6000 FHLBank Topeka — Denver Office . . . . . . . . ..... (720) 212‑9873 First Bankers’ Banc Securities Inc. (FBBS) . . . . . . ... (720) 709‑7613 GillCapital............................(303)296‑6260 HelloBello. . . . . . . . . . . . . . . . . . .......... (970) 946-6160 *ICBA Mortgage .. .. .. .. .. .. .. .......... (800) 253‑5356 *ICBA Securities . . . . . . . . . . . . . . . . . . . . . . . . (800) 422‑6442 IntraFi Network . . . . . . . . . . . . . . . . ......... (303) 706‑9265 Northland Securities Inc. . . . . . . . . . . . . . . . . . . . (303) 801‑3380 Olsen Palmer LLC . . . . . . . . . . . . . . . ........ (202) 803‑2620 Performance Trust Capital Partners . . . . . . . .... (312) 521-1000 Preferred Lending Partners . . . . . . . . . . . ...... (303) 861-4100 RocketPro. . . . . . . . . . . . . . . . . . .......... (704) 650-0622 Towne Mortgage Company . . . . . . . . . . ...... (303) 947-5244 USDA Rural Development . . . . . . . . . . . . ...... (720) 544-2916 West Gate Bank Mortgage . . . . . . . . . . . ...... (402) 434‑4116 LEGAL SERVICES Arnold&Porter. . . . . . . . . . . . . . . . . . . . . . . . .(303)863‑1000 Godfrey Law Group LLC . . . . . . . . . . . . ....... (303) 802‑6336 Markus Williams Young & Hunsicker LLC. . . . . . . . . (303) 830‑0800 Otteson Shapiro LLP (ICBC Counsel) . . . . . . . .... (720) 488‑0220 Spencer Fane LLP . . . . . . . . . . . . . . . ........ (303) 839‑3838 StinsonLLP . . . . . . . . . . . . . . . . . .......... (303) 376‑8400 Womble Bond Dickinson** . . . . . . . . . . . ...... (303) 623‑9000 LOAN REVIEW SERVICES EideBaillyLLP. . . . . . . . . . . . . . . . . . . . . . . . . .(303)770‑5700 Fortner Bayens PC . . . . . . . . . . . . . . . ........ (303) 296‑6033 ICBC LOBBYING AND PUBLIC RELATIONS The Capstone Group (ICBC Lobbyists) . . . . . . . . . . (303) 860‑0555 *ICBC Preferred Providers **Silver Associate Member ***Gold Associate Member 4 | INDEPENDENT REPORT
ICBC PREFERRED PROVIDERS ICBC Preferred Providers are selected by bankers just like you, so give them special consideration when considering their proposals for your bank! To learn more about ICBC’s Preferred Providers, contact the ICBC at (303) 832-2000. Please note: ICBC endorses the listed companies but not all products offered by the company. Contact: Scott Wintenburg | swintenburg@bbwest.com | (303) 291-3700 or (800) 601-8630 Merchant services from Bankers’ Bank of the West help you grow customer relationships with mobile payments technology, competitive unbundled pricing, efficient approvals and startups, responsive support and training. Contact: Keith Gruebel | kgruebel@bhg-inc.com | (954) 263-6399 Creator of the largest community bank loan network in the country. ICBC members can access the BHG Loan Hub, a secure, state-of-art loan delivery platform and the number-one source for professional loans. Contact: Wade Zirkle | wade@bluepointatm.com | (720) 295-9142 Colorado-based BluePoint ATM Solutions provides cost-efficient, reliable, branch and off-site ATM equipment and managed services to community banks across the Mountain West. From equipment sales/leases to custom installations, CIT, and ongoing service and maintenance — BluePoint provides dependable, cost-efficient ATM programs tailored to meet your bank’s needs. Contact: Phil Layher | phil.layher@ibtapps.com | (512) 616-1188 IBT Apps® is an empowering core partner to community banks nationwide, offering end-to-end core and digital banking solutions that meet today’s customer demands. Their adaptable i2Suite banking system enables your bank to streamline operations, control costs and mitigate risks. Transform your bank with the power of one total solution. Contact: icba.org/solutions | (866) 843-4222 The ICBC supports and recommends the following products and services supplied by our national association, the ICBA: ICBA Bankcard and TCM Bank, N.A.; ICBA Compliance & Risk Management; ICBA Mortgage; ICBA Reinsurance; and ICBA Securities. Contact: Mike Hatch | mike.hatch@ici-consulting.com | (316) 201-8590 Since 1994, ICI Consulting has helped banks and credit unions to assess, cost justify, evaluate and convert core processing, digital banking, EFT, lending, document imaging, CRM and branch solutions. Contact: Ryan Kast | ryan.kast@sbscyber.com | (605) 923-8722 SBS is your cybersecurity partner. Our offerings include: TRAC™ — Cybersecurity risk management software; Cyber-RISK™ — Automated FFIEC cybersecurity risk assessment software; IT and Network Security Audits; Consulting Services; Full Service Vendor Management; Role-Based Certifications; Vulnerability Assessments; Penetration Testing and more! Contact: Kyle Norman | kyle.norman@spglobal.com | (719) 661-3560 S&P Global combines exclusive analysis and in-depth data in real time for the banking, financial services and insurance industries. From bank branch data and government assistance programs to executive compensation and league tables, S&P is the final word in business intelligence on financial institutions. Contact: Madeline Dickman | mdickman@travelers.com | (720) 200-8293 Offering a wide range of customized insurance protection, Travelers SelectOne+® for financial institutions is designed to respond to the most recent trends in banking. INDEPENDENT REPORT | 5
FLOURISH Rising Concerns Over National Bank Trust Charters Over the past few years, we’ve witnessed an alarming upsurge in the number of nonbank financial technology firms applying for national bank trust charters. We can track this trend back to a shift in policy in 2021 (Interpretive Letter #1176) in which the Office of the Comptroller of the Currency (OCC) reinterpreted the trust charter to eliminate its exclusive focus on fiduciary activities and redefined it to create an opening for digital asset firms to apply. There are many fundamental issues with this interpretation, including: 1. Safety and Soundness Concerns: The digital asset providers applying for this charter bring unique risks that require sufficient supervisory and regulatory safeguards. Trust banks are not required to meet the same kinds of regulatory and capital standards that apply to federally insured full-service banks. Granting carte blanche to these higher-risk entities also exposes the banking system to deposit drainage and increased fraud. 2. Policy Inconsistency and Risk: The charter was designed for one purpose: conventional trust companies providing custodial services for trust beneficiaries. Opening up access to digital asset firms does not align with that intent or statutory parameters. That lack of policy consistency creates risks in the banking sector. 3. Unfair Competitive Market: Nonbank financial technology firms are using these charters to circumvent traditional regulatory requirements. The charters allow these firms to function like banks but without the regulations that are required of banks. This creates an uneven and risky playing field. ICBA has called on the OCC to rescind Interpretive Letter #1176 and undertake a formal rulemaking on the national trust charter to By Rebeca Romero Rainey, President & CEO, ICBA clarify its scope and alignment with congressional intent. We are also continuing to comment on individual applications as they come through; engaging repeatedly with the OCC to voice concerns; and providing education through media interviews, press releases, blog posts and more to keep a focus on this alarming trend. We need your help, too. Stay engaged on this topic. Comment on applications and remain aware of emerging issues. Educate your legislators. Armed with knowledge, we’ll be better able to respond. It will take our unified voices for this issue to be addressed. Fortunately, when it comes to advocating for the safety and soundness of our banking system, community bankers always rise to the challenge. 6 | INDEPENDENT REPORT
For community banks, digital transformation has moved from an industry colloquialism to a punch list reality. While we have always offered exceptional digital services that complement relationship banking, the emergence of artificial intelligence, the demand for integrated experiences and the 24/7 nature of banking have taken our plans to the next level. And therein lies the potential. While our tech stack has historically been a cost center, we must now think of it as an opportunity. Consider how data dashboards could deliver insights that allow your team to market to customers in ways that directly resonate with their preferences. Think about how a product like a personal finance manager may help your wealth management business by steering customers to market opportunities. Or look at small business products that integrate bookkeeping into your banking app, allowing customers to enter invoices and pay bills from one consolidated, secure location. Technology allows us to expand our services in ways that align with customer needs, and these offerings only scratch the surface of what is available. With core providers more open to fintech integrations, we can cast a larger net around the products and services that address a strategic need. To that point, our digital transformation efforts can also support the internal workings of our banks. The tech solutions my community bank has rolled out most recently are focused on helping detect fraud, which has become our biggest priority for the year. We have integrated new services to clamp down on attempted ACH and wire fraud, and we have real-time integrations that allow us to stay on top of transactions. We have also become a lot more proactive, using a new product that we found through ICBA’s ThinkTECH Accelerator (icba.org/accelerator) to scan the dark web for customer information and take precautionary steps when we see something. Fortunately, as we continue to advance our digital offerings, ICBA has programs that help, and I encourage you to explore them. Come to ICBA LIVE (icba.org/live) from March 6-9, 2026, and meet with providers. Sit in on the ThinkTECH showcases to learn about new technology offerings for community banks. Review the Solutions Directory (solutions.icba.org) for companies already vetted by ICBA. I, for one, am truly grateful to have ICBA as a partner as my bank grows its digital presence, one solution at a time. It’s with that same sense of gratitude that I say I am thankful for this community of community bankers. Wishing you and yours a wonderful holiday season! FROM THE TOP MY TOP 3 Things I’m grateful for: 1. My growing family — I have two new granddaughters to join my grandson! 2. My ICBA family. 3. Fall football season. Digital Banking for the Modern Age By Jack E. Hopkins, Chairman, ICBA INDEPENDENT REPORT | 7
52nd ANNUAL CONVENTION RECAP Nearly 300 attendees laced up their boots and joined us for an unforgettable 52nd Annual Convention this September at The Hythe in Vail, Colorado. ICBC extends a heartfelt thank you to everyone who attended, sponsored and exhibited. You helped make this year’s gathering one for the camp history books. 8 | INDEPENDENT REPORT
As always, our convention delivered a full itinerary of professional development, meaningful connections, new vendor discoveries and a strong sense of community spirit. From sunrise to late-night campfire conversations, Camp ICBC offered something for every camper. The opening reception on Wednesday evening set the tone, giving colleagues and friends a chance to gather around the campfire, swap a few fishing stories, raise a glass and get a first look at the annual ICBC High School Scholarship auction items. Thursday morning began with the annual meeting and the announcement of ICBC’s 2025-2026 officer slate. Congratulations to: • Mike Hurst, President, Del Norte Bank, ICBC Chairman • Joe Martinez, President and Chief Lending Officer, San Luis Valley Federal Bank, ICBC President • Robert Holt, Senior Vice President and Senior Credit Officer, North Valley Bank, ICBC President-Elect We also extended sincere appreciation to our outgoing chairman and board members for their service and leadership: • Tom Ogaard, President and CEO, Native American Bank, Chairman • Sean Lening, President, GNBank, Eads, District C • Wade Gebhardt, Corporate President, Mountain Valley Bank, Steamboat Springs, District D
As always, our convention delivered a full itinerary of professional development, meaningful connections, new vendor discoveries and a strong sense of community spirit. We gave a warm welcome to new district directors: • Jamie Santistevan, Senior Vice President and Chief Operating Officer, Native American Bank, District A • Kent Jones, President and CEO, Flatirons Bank, District A • Peter Page, Senior Vice President and Chief Operating Officer, Frontier Bank, District C Derek B. Williams, ICBA Past Chairman and President and CEO of Century Bank & Trust in Milledgeville, Georgia, concluded the meeting with a timely industry update and an ICBA brief. Camp ICBC then got down to business with two general sessions, beginning with “The Gift of Influence” from Tommy Spaulding. The second session was an expert panel on fraud, payments and loan review trends moderated by Bud Hollenkamp, Partner, Forvis Mazars, with insights from panel members Scott Wintenburg, Senior Vice President and Chief Growth Officer, Bankers’ Bank of the West; Brian Blauser, Supervisory Special Agent, FBI; and Mark Weitekamp, Managing Director, Forvis Mazars. At lunch, we recognized the four Graduate School of Banking at Colorado (GSBC) scholarship recipients: • Amber Hardwick, Wray State Bank, Wray • Max Meints, FirstBank, Erie • Jon Riedel, The Dolores State Bank, Dolores • Scott Schlegel, Alpine Bank, Breckenridge These $2,000 scholarships are given annually to the four top-performing Colorado-based ICBC member bank students and are applied to their tuition for their final year at GSBC. In addition, five high school scholarship recipients were honored: • Jon Bradley • Bay Ellis • Kieran Harris • Quentin Kramer • Lucas Lovato Each student received a $1,750 one-year scholarship. We are excited to follow these 10 | INDEPENDENT REPORT
young people on their individual journeys of academic success. After lunch, and after enjoying the crowd-favorite s’mores ice cream sandwiches, campers dove into two rounds of professional learning sessions. Thank you to our expert presenters for helping attendees earn new merit badges in banking excellence: • Inflation, the Fed, and Balance Sheet Management — Michael Benedict, Stifel • Turning Your Traditional Commercial Lenders Into Fierce Deposit Hunters — Matt Regn and Ted Rosen, Expert Business Development • Disruption: Navigating Today as a Community Bank CEO — Connie West, The James Paul Group • Compliance Hot Topics — John Podvin and Jenny Small, Otteson Shapiro • Financial and Other Banking Trend Perspectives — Ryan Abdoo, John Byczkowski, Cooper Dayton, and Andrea Pech, Plante Moran • Bots, Brains & Banks: Using AI in Banking While Managing Risk — Chris Tuzeneu, Bankers’ Bank of the West • Engagement is Falling: Rebuilding Culture in Community Banks — Connie West, The James Paul Group • Preparing for All Weather Growth — John Curlin, Performance Trust Capital Partners Thursday evening brought a full dose of camp spirit: camp-themed cocktails, lively conversations, dinner and a couple of friendly rounds of Family Feud. The night wrapped up with Rich Bratten (Bank Compensation Consulting) and Friends leading a lively campfire sing-along that kept the campers entertained well into the evening. A huge thank you to the generous donors, enthusiastic bidders and dedicated volunteers who helped make this year’s ICBC High School Scholarship auction a standout success. On Friday, campers gathered for two final sessions: “An Economic Outlook” with Nicholas Sly of the Federal Reserve Bank of Kansas City, and “Stablecoin and Digital Assets: Where Do We Go from Here?” presented by Amy Ledig of ICBA. Both provided the kind of big-picture guidance that helps community banks chart their course with confidence. Even as we packed up our gear and headed home from Camp ICBC, we were already marking our calendar for next year’s adventure. Join us Sept. 16-18, 2026, when we return to The Hythe in Vail for ICBC’s 53rd Annual Convention. INDEPENDENT REPORT | 11
Richey May A Conversation with Michael Nouguier and Brent Murray For 40 years, Richey May has provided assurance and advisory services to clients throughout the United States, helping organizations of all sizes translate complex technical concerns into clear executive decisions. Richey May began its advisory practice about eight years ago with an emphasis on technology, and subsequently, cybersecurity became one of the practice’s largest focuses. Their goal is to empower every organization to thrive securely. They work with small, one- and two-person organizations, as well as Fortune 500 clients. We recently had the opportunity to speak with Michael Nouguier, Partner, Cybersecurity Services & CISO, and Brent Murray, Director of Strategic Alliances, and learned more about the company. The following are excerpts from our conversation. Tell us a little bit about yourself. Michael: I have 20-plus years of experience in IT and cybersecurity, leading large organizations and consulting practices. I’ve worked in various industries, but primarily in financial services, which is where we now focus most of our attention at Richey May. Brent: I’ve had 12 years of working within associations. I’ve always been fascinated by small, intricate communities, such as those found in associations. You can make an incredible impact within these communities with focus, hard work and being intentional. What makes your company unique? Michael: We have an unlimited training budget. Our team is capable of taking any training that they want that bolsters the team’s knowledge and skill sets. We attend all the major industry conferences, including Black Hat, DEF CON and local security conferences, to ensure that we stay up-to-date with local trends. We have mapped out and follow the industry standard for cyberattacks, which is the MITRE ATT&CK framework. That framework has documented the DNA of cyberattacks and each aspect of a cyberattack. There are over 600 different things that can happen during a cyberattack, but not many new ones are being added. It’s just a matter of understanding the unique ways that cybercriminals are employing these tools, tactics and techniques. Many people think cybersecurity is a mix of good and bad actors behind keyboards, typing simultaneously, whoever types faster wins, but that’s not what it is. Cybersecurity is not necessarily about preventing every hack that comes in. It’s a matter of building resilience so that when an attack happens, you’re prepared to take it on and prevent it from causing true damage. We want you to thrive securely. Brent: The majority of community banks don’t have the ability to go out and hire a full team of cybersecurity specialists. They might have an IT person or small team that has some cybersecurity background and knowledge, but to be able to protect an entire bank from a cyberattack is challenging. Community banks should, if not already, be looking for vendors with whom they can work, similar to Richey May. We understand the compliance side of the banking industry. We also understand where bad actors are most likely going to try to break into your company. We can then come up with a strategy to help make sure that not only do you have the right tools in place, but also a plan for handling any incidents that may occur. There’s so much creativity in how to solve problems when it comes to cybersecurity and there are so many different devices, applications, physical hardware, software and on and on that companies have to plan for and consider in their strategy. I think leveraging a Cyber Advisory Firm like Richey May helps cut through all the noise and can streamline the process for thriving securely. That’s the real value in working with us. What do you love about your job? Why is being a member of ICBC important to you? Michael: I love the challenge that each new day brings. Every customer is different. Every network is different. Being able to strategize and help drive proactive measures or respond to an incident is thrilling. Brent: I love that I get to be creative and have the autonomy to focus on making an impact within communities. I truly enjoy building relationships and finding different ways to bring value to the people around me, especially within associations. Being a member of ICBC is important to me, because I see an opportunity for Richey May to be a valuable resource to this community. I think we can bring a lot of education and awareness to the group and help provide guidance and support when needed. We are grateful for the opportunity. To learn more about Richey May and what they can do for your community bank, please visit richeymay.com. ASSOCIATE GOLD MEMBER SPOTLIGHT Michael Nouguier Brent Murray 12 | INDEPENDENT REPORT
HOW JACKPOTTING WORKS In its simplest form, jackpotting involves two components: access and control. Criminals gain physical access to an ATM — often during off-hours — by disguising themselves as technicians. Once the cabinet is opened, attackers install specialized hardware or upload malware through a USB or network port. With control of the system, they can command the ATM to dispense large volumes of cash on demand, sometimes emptying a machine in minutes. The Mountain West is especially vulnerable for two reasons. First, many rural banks still operate older ATM models, which are more susceptible to known jackpotting exploits. Second, the vast geographic spread of service areas can delay detection and response, allowing criminals more time to operate undetected. TRENDS EMERGING IN THE REGION 1. Shift From Large Cities to Middle Markets in Rural Areas While early jackpotting reports in the U.S. centered on large urban areas, more recent activity is concentrated in mid-sized cities and smaller rural markets. Law enforcement officials suggest that organized crime groups are deliberately targeting banks with fewer resources for ATM monitoring and security. 2. Cross-Border Coordination Authorities warn that many jackpotting incidents in the Mountain West are linked to organized groups operating across state — and sometimes national — borders. I-25 and I-80 provide quick exit routes, and some investigations have tied attacks in Wyoming and Colorado to crews operating out of southern California or even Mexico. In April, two Venezuelan nationals were indicted by the DOJ for conspiracy to defraud over 30 ATMs across several western states — including Colorado, Utah, and California. One attack alone netted nearly $94,800 from a Merced County credit union. 3. Increase in “Black Box” Attacks A notable regional trend on the rise is “black box” jackpotting. Instead of uploading malware directly into an ATM’s operating ATM Jackpotting Trends in the Mountain West A Growing Threat to Community Banks — What You Can Do To Mitigate the Risk By Wade Zirkle, President & CEO BluePoint ATM Solutions, ICBC Preferred Provider and ICBC Associate Member ATM jackpotting — a form of cyber-enabled theft in which criminals manipulate ATMs to dispense cash illicitly — has historically been more prevalent internationally. Over the last decade, however, the tactic has steadily gained a foothold in the United States, with community banks across the Mountain West now finding themselves in the crosshairs. Jackpotting has emerged as a sophisticated threat in our region, blending physical crime with the deployment of advanced malware. This surge is part of a broader escalation: The U.S. Secret Service noted that losses from jackpotting attacks reached approximately $6 million in 2023 across some 200 incidents, and by early 2024, similar losses had already occurred from over 300 attacks. The OCC echoed these warnings in spring 2025, urging banks to shore up both cyber and physical defenses amid increasing ATM “cash-out” risks. 14 | INDEPENDENT REPORT
system, attackers bypass the machine’s software entirely by connecting an external device to the cash dispenser unit. This is more difficult for banks to detect, as it leaves minimal digital traces. 4. Combination With Other Financial Crimes Jackpotting is increasingly being combined with skimming and account-takeover schemes. In a recent case in Arizona’s northern corridor, criminals compromised ATMs to harvest card data while simultaneously deploying malware to empty machines. The convergence of digital and physical crime complicates investigations and heightens losses. IMPACT ON COMMUNITY BANKS For community banks in the region, jackpotting presents both financial and reputational risks. Losses from a single event can reach hundreds of thousands of dollars, and the perception of insecurity can undermine customer confidence. Smaller institutions also face disproportionate challenges: Unlike national banks, they may not have in-house cybersecurity teams or the capital to replace vulnerable ATM hardware immediately. Banks in the region are taking steps to adapt. Recommended countermeasures include: • Update Regularly: Ensure that the ATM’s operating system, firmware, software and configurations are up to date. • Upgrade Machines: As necessary, upgrade ATM fleets to newer models with encrypted communications and hardened ports. • Delay Physical Access: Use anti-jackpotting kits, alarms and barriers to delay attackers. • Monitor Remotely: Improve remote monitoring to detect unusual cash-out patterns in real time. • Upgrade Technology: Ensure ATMs are TLS-encrypted and have TR31 PCI-compliant keypads. • Monitor Anomalous Activity: Implement real-time surveillance, including AI-assisted alerts and transaction anomaly detection. • Educate Staff: Train personnel to identify impersonators and unauthorized technicians. • Limit Physical Access: Generic manufacturer keys can lead to stealing, copying or purchasing keys to access multiple ATMs. • Implement Access Controls: ATM service technician access should require multi-factor authentication where possible. If you suspect that an ATM is compromised using these jackpotting techniques, take the following steps immediately: • Before opening the ATM, wear gloves to avoid contaminating any potential DNA evidence and prints. • Before removing any unauthorized devices from the ATM, photograph all components, the hard drive and any attached devices. • Report suspicious activity to the U.S. Secret Service field office in Denver by calling (303) 850-2700. INDEPENDENT REPORT | 15
Since we started seeing Halloween decorations in August, I felt it was high time we started thinking about the holiday season. More specifically, as it relates to community banking. And still more specifically, about a checklist for the balance sheet. There are some seasonal items that bear attention prior to, and immediately after, year-end. So let’s take a look at what may be on the radar for the fourth quarter. GAIN/LOSS HARVESTING I have the same access to industry-wide bank performance reports that any of you do, and I also make it a point to ask bankers how their years are going while traveling the country. The numbers and the commentary have been in sync this year, which isn’t always the case. It sure looks like 2025 is going to conclude favorably for community banks in general. By extension, that means a lot of you are going to be ahead of budget. That happy dynamic will naturally lead management teams to consider options for fine-tuning their earnings. There are some current variables that give bankers a lot of flexibility in timing their income recognition. For example, the average bond portfolio has a market loss of about 5%, which is the lowest percentage since March 2022. This means that some individual positions have gains, and some have losses. So there are probably some combinations of sale candidates that can produce the desired amount of realized income/loss. A friendly reminder: If your bank is looking for gains, make sure they are not from tax-free bonds. This brings up a related activity … SBA SECONDARY MARKET The Small Business Administration’s flagship 7(a) program set a record of $37 billion of closed loans in fiscal 2025. This means more banks have more SBA products in their loan portfolios than ever, and the guaranteed portions (usually 75%) are probably the most liquid loans on a bank’s balance sheet. They can quickly be sold to one of the consortium of SBA poolers at substantial gains. Because the guarantees are always going to demand a premium in the secondary market (due to their full-faith-and-credit status and floating rate structure), many sellers will wait until the fourth quarter to sell, when the bank’s annual earnings are coming into focus. Inside scoop: The poolers are usually besieged with bid lists as the last quarter progresses, so most reduce their bids to smooth out their purchase commitments. Some years, it takes until February for market indigestion to subside. So the suggestion here is to sell your Making a List, Checking It Twice Year-End Is Approaching. Here Are Some Seasonal Reminders. By Jim Reber, President & CEO ICBA Securities, ICBC Preferred Provider and ICBC Associate Member 16 | INDEPENDENT REPORT
7(a) loans as they’re closed to more efficiently capture the gains. RISK MANAGEMENT Bankers know intuitively that best practices for risk management include regular assessment of projected cash flows, collateral positions, alternative funding sources and contingency funding plans. What may have changed in the last six months is the increased possibility of a lower interest rate environment for next year. Depending on a given bank’s asset/liability posture and its bond holdings, it could mean additional, and perhaps unwelcome, cash flows. A silver lining is that the average bank now owns its bonds at an average price slightly below par (99.86), so prepayments and calls should have little immediate impact on yields. There have been times in this decade when the average book price was nearly 103.00. HOUSEKEEPING Also, the ever-popular policy reviews are coming up on the tickler file. Examiners are wont to ask how recently your troika of policies (i.e., investment, interest rate risk and liquidity) has been updated. Lately, the liquidity policy has gotten a lot of scrutiny, as community bankers have told me. The good news is that there has been no significant literature from the regulators this year that would require a major rewrite. Your brokers and/or A/L modelers should be able to provide some templates, guidance and assistance if necessary. While you’re getting your board of directors to sign off on updated policies, management should ensure these items are fully documented: • Approved broker-dealers • Full list of vendors (with SOC-2 audits if applicable) • Director onboarding and continuing education • Minutes of committee and full board meetings • Execution of risk management strategies, such as interest rate swaps or loan sales • Rationale for, and economics of, bond swaps, with back testing if appropriate There you have an end-of-year checklist, just in case you’ve forgotten or run out of to-dos. Again, thanks to the favorable economic backdrop for most regions of the country this year and the careful stewardship by most community bank management teams, there don’t seem to be any dumpster fires to fight this year. I will update this column with some ideas on how to launch a successful 2026 as soon as I start seeing Easter decorations. Happy holidays! Jim Reber (jreber@icbasecurities.com) is president and CEO of ICBA Securities, ICBA’s institutional, fixed-income broker-dealer for community banks. PAUL STAN 303.260.5109 bsidecapital.org client-relations@bside.org KYLE KLABUNDE 720.514.1178 WE SIMPLIFY SBA LENDING Partner with B:Side on your next SBA 504 or 7(a) project. CONTACT US INDEPENDENT REPORT | 17
Deposit competition remains fierce. According to IntraFi’s latest survey of bank executives, 93% say they expect deposit competition to remain at current levels or increase over the next year.1 To stay competitive in the current environment, community banks need every tool in their arsenal to attract and retain large-dollar depositors like businesses, nonprofits, government entities and high-net-worth individuals. A reciprocal deposit network, which enables banks to attract and retain loyal, franchise-building customers by offering access to multi-million-dollar aggregate FDIC insurance across a bank network, is one such tool. Per recent research published by the Federal Reserve Bank of Dallas, reciprocal deposit networks get an outsized share of deposits from small and mid-sized banks. “Reciprocal deposits represented 6.47% of total deposits for banks with less than $10 billion in assets in the first quarter, up from 6% at the end of first quarter 2024. Among institutions with assets of $10 billion to $100 billion, such deposits accounted for 6.2% of total deposits as of March 31, 2025, down only slightly from year-end 2024 but up from 6.1% at the end of first quarter 2024.”2 WHY ARE COMMUNITY BANKERS INCREASING THEIR USE OF RECIPROCAL DEPOSITS? Use of reciprocal deposits saw a significant uptick after 1) the 2018 Economic Growth, Regulatory Relief and Consumer Protection Act, which recognized most reciprocal deposits as nonbrokered deposits, and 2) spring 2023 bank failures. Since then, small and mid-sized banks have maintained their heightened usage patterns. Per the Economic Growth, Regulatory Relief and Consumer Protection Act, reciprocal deposits held by an FDIC-insured depository institution are reportable as nonbrokered if 1) the bank is well capitalized and has received an “outstanding” or “good” on its most recent examination, and 2) the total amount of reciprocal deposits held does not exceed the lesser of $5 billion or 20% of the bank’s total liabilities. With this new (in 2018) characterization of reciprocal deposits — and because reciprocal deposits tend to be lower-cost deposits that come in large increments from local customers — more banks embraced reciprocal deposits as an attractive option for growing franchise value. Then, the high-profile bank failures in spring 2023 drew attention to the risks for bank customers who have cash balances greater than the FDIC-insured maximum of $250,000, thereby increasing demand for large deposit safety. A survey of bank executives at the time revealed that 68% of respondents experienced an increase in inquiries about the safety of their deposits.3 The awareness that uninsured deposits pose a risk to bank customers, particularly those who need daily access to operational cash, increased after the 2023 banking crisis and has remained sporadically in the news. GOOD FOR BANKS AND COMMUNITIES As more community banks utilize reciprocal deposits, they realize how nicely reciprocal deposits dovetail with their community missions. With reciprocal deposits, the full amount of funds placed can stay local to support community lending. This has special appeal for community banks that, by design, exist to help their communities grow and thrive by lending to local customers. Community banks play a vital role in local economic stability and growth. By using reciprocal deposits, banks can expand their lending capacity for their local customers, creating a virtuous cycle of mutual success. 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 of IntraFi network banks can be found at www.intrafi.com/network-banks. Certain conditions must be satisfied for “pass-through” FDIC deposit insurance coverage to apply. Strengthening Franchise Value Why Community Banks Are Growing Their Use of Reciprocal Deposits By Joseph Hooker, Chief Sales Officer IntraFi, ICBC Associate Member 1. IntraFi Q3 2025 Bank Executive Business Outlook Survey. 2. Docherty, Christine, and Alessio Saretto. “How Do Reciprocal Deposit Networks Interact with Deposit Insurance?” Federal Reserve Bank of Dallas, accessed August 27, 2025. https://www.dallasfed.org/research/ economics/2025/0805. 3. IntraFi Q1 2023 Bank Executive Business Outlook Survey. 18 | INDEPENDENT REPORT
MARCH 6-9, 2026 San Diego Convention Center Community. Learning. Innovation. Discover What Makes ICBA LIVE Unforgettable San Diego sets the stage for the largest gathering of community bankers in the world. This is the event where connections are made, ideas are sparked, and strategies are shaped. From powerful keynote speakers and immersive learning labs to high-energy networking events and cutting-edge fintech showcases, ICBA LIVE offers something for every attendee. Register Today At icba.org/live
When colleagues asked me to lead an AI training a few years ago, I wasn’t an expert. What became clear quickly was that AI would reshape financial services faster than expected. Today, every bank — no matter the size — needs to think seriously about AI strategy and policy. WHY IT MATTERS 1. The rapid evolution of AI is unlike anything we’ve seen. What was experimental a year ago is now in the hands of your employees and customers. 2. Its use is revolutionary and already embedded in banking operations. 3. AI is here to stay. Federal agencies and Congress are focused on consumer risk and financial system stability, issuing new guidance almost monthly. HOW IT STARTED The term AI dates to a 1950s academic conference, describing the goal of replicating human thought through machines. Recent advances are visible in search engines like Google, which now provide AI-generated summaries. Initially unreliable, accuracy has improved exponentially. Think of AI’s trajectory like the automobile’s. Early cars were costly, slow, dangerous and required mechanical skill. Over time, they became safer, faster and ubiquitous. Similarly, AI will grow more reliable as quantum computing accelerates processing, proprietary tools expand use cases and viral adoption improves data inputs — reducing errors and enhancing trust. Standards for safe use will follow, just as auto safety regulations did. AI — It’s Not Just for Drafting Your Holiday Updates Why Every Colorado Bank Needs an AI Policy Now By Jenny Small, Partner Otteson Shapiro, ICBC Associate Member BANK USE CASES AND RISK MANAGEMENT AI impacts banking far beyond search engines. Key applications include: • Fraud and AML monitoring • Credit underwriting and risk models • Account opening and identity verification AI is now a national priority, likened to the moon race. Recent milestones: • Dec. 2024: House AI Task Force report • May 2025: GAO report on AI in financial services • July 2025: White House “Winning the Race: America’s AI Action Plan” • Sept. 2025: NIST AI Standards pilot feedback deadline Add state legislation to the mix, and the focus is undeniable. Regulators are following suit: • OCC: Requested AI feedback (Oct. 2024) • Fed: Launched AI Program (Dec. 2024) • FDIC: AI compliance plan (Dec. 2024) • NCUA: AI in Government Act compliance plan (July 2025) This attention signals the need for documented AI policies, procedures and oversight now. BUILDING YOUR BANK’S AI POLICY Banks must act. Start with strong due diligence, trusted vendor partnerships and legal guidance. Robust policies will help your bank leverage AI’s benefits, manage risks and stay ahead of evolving standards. INDEPENDENT REPORT | 21
Digital transformation in banking is reshaping how financial institutions operate and engage with customers. However, as digital capabilities expand, so does the attack surface. From mobile banking to AI-powered automation, the modernization of the financial sector requires a cybersecurity strategy that keeps pace and is integrated at every stage of transformation. The future of banking is not just about better technology. It’s about building secure, resilient systems that inspire customer trust. Cybersecurity in banking isn’t a separate initiative but rather a foundational thread that must run through every phase of the digital transformation journey. WHAT IS DIGITAL TRANSFORMATION IN BANKING? Digital transformation in banking involves reimagining banking operations, customer engagement and internal workflows using digital technologies. It’s more than digitizing services — it requires embracing a technology-first culture that fosters innovation, drives efficiency and builds resilience across the organization. Customers today expect more than just new technology. They want experiences that are fast, intuitive and secure. Whether accessing accounts via mobile apps or interacting with automated services, users expect digital transformation to improve both convenience and protection. Meeting these expectations is essential to earning trust and staying competitive. And the shift is accelerating: Global investment in digital banking technologies is expected to reach nearly $14 billion by 2026, representing an annual compound growth rate of more than 11%, according to MarketsandMarkets. Digital transformation impacts every aspect of banking, from behind-the-scenes operations to customer-facing services. Examples include: • Upgrading legacy core systems to scalable, cloud-based infrastructure • Using AI to enhance fraud detection, underwriting and customer support • Streamlining customer onboarding and authentication through digital identity tools • Expanding access to financial services via mobile apps and remote platforms • Modernizing risk management, compliance tracking and regulatory reporting To succeed, banks must shift their strategy, upgrade their architecture and embed cybersecurity into every layer of that evolution — not just as a final step but from the ground up. CYBERSECURITY IN BANKING: THE BACKBONE OF DIGITAL TRUST Cybersecurity must evolve alongside digital transformation. In banking, that means shifting from a reactive function to a proactive, embedded discipline. With cyberattacks growing in sophistication and scale, relying on legacy defenses is no longer an option. To build digital trust and secure every layer of operations, modern cybersecurity strategies should include: • Proactive security practices, such as regular risk assessments, incident response planning, business continuity strategies and technical safeguards • Continuous monitoring and identity controls, especially as banks adopt cloud infrastructure, mobile platforms and open banking APIs • Robust third-party risk management, including secure APIs, vendor due diligence and regular assessments as digital ecosystems expand • Strong regulatory alignment, with processes in place to protect consumer data and demonstrate compliance to both regulators and customers • Modernized governance programs, with information security programs that are streamlined, current and followed by all employees Together, these practices help ensure cybersecurity isn’t just a support function but rather part of the institution’s DNA. Digital Transformation in Banking The Role of Cybersecurity in Modern Banking By Chad Knutson, CEO SBS CyberSecurity, ICBC Preferred Provider and ICBC Associate Member 22 | INDEPENDENT REPORT
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