2026 ISSUE 1 A PUBLICATION OF THE INDEPENDENT COMMUNITY BANKERS OF COLORADO BUILDING ON THE PAST, BANKING ON THE FUTURE. Navigating the Evolving Landscape of Community Banking Driving Innovation With AI Empowering Financial Institutions With AI‑Powered Document Classification
©2026 The Independent Community Bankers of Colorado (ICBC) | Memberlink Solutions DBA 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 CEO Bankers’ Bank of the West Christian Otteson Partner Otteson Shapiro LLP 2 | INDEPENDENT REPORT
20 CONTENTS 7 12 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 2026 PUB. 5 ISSUE 1 4 Support the ICBC’s Associate Members! 5 ICBC Preferred Providers FLOURISH 6 Let’s Continue the Course in the New Year By Rebeca Romero Rainey, President and CEO, ICBA FROM THE TOP 7 Setting Our Priorities for 2026 By Jack E. Hopkins, Chairman, ICBA 8 Confidence in the Program Why SBA Lending Holds Steady When the World Does Not By B:Side Capital, ICBC Associate Member 10 Industrial Loan Bank Charters The Footnote Penciling in Its Own Chapter By John Podvin, Partner, and Jenny Small, Partner, Otteson Shapiro, ICBC Silver Associate Member 12 Navigating the Evolving Landscape of Community Banking By Ryan Abdoo and John Byczkowski, Plante Moran, ICBC Silver Associate Member 14 Why Your Website Is Losing Visitors — and How To Fix It Fast By Bella Ruscheinski, Solutions Project Manager, Spry Inc., ICBC Associate Member 16 The Importance of Strategic Planning For Success in 2026 and Beyond By Connie West, Gallup Certified Strengths Coach, Regional Vice President, The James Paul Group, ICBC Associate Member 17 Moving Beyond ‘Set It and Forget It’ Elevating Portfolio Management From Passive To Purposeful By Andrea Pringle, Financial Strategist, MBS Analyst, The Baker Group LP, ICBC Associate Member 18 Driving Innovation With AI Empowering Financial Institutions With AI-Powered Document Classification By Alogent, ICBC Associate Member 20 2026 Industry Outlook Community Bankers’ Top Challenges, Investments and Opportunities By Jason Young, Vice President of Product Management, CSI, ICBC Associate Member 22 How Deposit Flows Are Reshaping the U.S. Banking Landscape By Tim Groth, Vice President, Data Analytics, IntraFi, ICBC Associate Member 23 It’s Time To Hit the Weights By Jim Reber, President and CEO, ICBA Securities, 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 . . . . . . . . . . ..... 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(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 RMCyber***...........................(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: 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
Each day in community banking seems to dawn with a new issue, but taking a step back, our challenges are all in a day’s work. The common theme among all our battles is that they aren’t new; they are ones we’ve faced for decades, just with new faces. For example, whether we’re talking about credit unions, industrial loan companies (ILCs) or crypto firms, we’re battling against entities trying to call themselves “banks” without a level playing field and the rules to support it. While their models and approaches might look a little different from one another, the core issue remains the same. Our focus, as it always has been, is to address unfair advantages, advocate for the mission of community banking and center on ways we can better support our local communities. How, amid these battles, will we retain capital to serve our local communities? That answer stands at the core of all of our positions. SUPPORTING YOUR COMMUNITY THROUGH ICBA’S CORE PILLARS As the landscape around us changes, so, too, do our opportunities. Knowledge is power, and being armed with the right information gives us the ability to address new potential. That’s why ICBA Education offers ways to support you in deepening your understanding of pivotal subjects. With deeper insights into technologies such as digital assets and stablecoins, AI, and more, you can unveil ways to institute proactive strategies at your community bank. Of course, innovation also plays a key role in supporting our communities, so ICBA Innovation continues to seek out providers that build solutions for community banks. We work to introduce options that help you to achieve your goals in line with what makes sense for you and your market. On the advocacy front, we continue to ensure clear pathways for community banks to engage with rulemakers. We will drive conversations with Congress, the administration and regulators as we continue to protect the distinction between community banks and other entities. ONE TOPIC AT A TIME In some ways, it’s reassuring that today’s issues are a varietal of what we have faced for years, but there is no question that the pace of change has accelerated. It is more important than ever to ensure you, your team and your board are actively engaged in these conversations and leveraging the power of the tools ICBA provides. Just as I’m certain that 2026 will introduce new issues, I also know that as a community of community banks, we are prepared to tackle them together, one topic at a time. FLOURISH Let’s Continue the Course in the New Year By Rebeca Romero Rainey, President and CEO, ICBA 6 | INDEPENDENT REPORT
Setting Our Priorities for 2026 FROM THE TOP By Jack E. Hopkins, Chairman, ICBA There’s something about the new year that brings with it a clean slate and a fresh start. As we continue through 2026, we have the opportunity to shape where we want to go. For my community bank this year, the strategic focus is on efficiency. MAKING THE LEAP It’s one thing to set the objective, and another to implement it. So, we’re evaluating and investing in solutions that start with the back office. For us, it’s a purposeful decision so that we can update our technology before we revamp it for customers. We’ve established a team to assess departmental operations at the bank and determine where we can streamline them. Within that team, we’ve recruited some younger, more digitally native bankers from middle management who are technology-savvy and will be the staff who must navigate these solutions into the future. We’re also exploring areas with higher turnover. Those numbers tell a story that the jobs aren’t as satisfying as they could be. We are using this opportunity to identify how we can make them more engaging and support greater retention in the process. As we move into implementation, we are looking to identify solutions that are specifically geared toward community bank challenges. We’re focusing our search on ICBA ThinkTECH Accelerator alumni, Preferred Service Providers and Corporate Members. We plan to do a deeper dive at ICBA LIVE and leverage past showcases in which we’ve participated, as well as previous LIVEs we’ve attended, to help narrow our shortlist of potential partners. ADDITIONAL PRIORITIES In addition to efficiencies, we are prioritizing digital assets and stablecoin knowledge-gathering this year. With the way the landscape is heading, we need to keep up to date on policy discussions to make sure we’re not behind the eight ball. We are also taking advantage of ICBA Education to learn about the implications of these developments for the future and how these technologies might be applied to our banks. With these strategic priorities in mind — which I bet are on many of your lists as well — I encourage you to come to ICBA LIVE, taking place March 6-9 in San Diego, to attend the sessions and identify possible partners. Also, join us in D.C. for the ICBA Capital Summit, May 4-7, to ensure your voice is heard on these and other percolating issues. Although we have a blank canvas to shape the year ahead, we are in a time where what you do now will affect your community bank for years to come. Thankfully, we have ICBA as a resource to help us navigate what’s next. INDEPENDENT REPORT | 7
By B:Side Capital ICBC Associate Member There is no shortage of reasons to feel uneasy right now. Economic signals are mixed. Politics are loud and unresolved. Geopolitics remain unsettled. Social institutions feel stretched thin. None of this is new, but the overlap is what makes this moment feel heavier. History would call this a pressure phase. A period where systems are tested not by a single shock, but by sustained strain. In moments like this, the instinct is to retreat. Capital pulls back. Decision-making slows. Risk tolerance collapses into caution. Yet history also shows that some systems do not just survive these periods. They quietly prove their value. SBA lending is one of those systems. Across crisis eras, from the financial crisis to the pandemic and into the current adjustment cycle, SBA lending has played the same role again and again. It acts as connective tissue between lenders who want to lend and businesses that still need to build, buy, hire and adapt. That role matters most when uncertainty is highest. Part of what makes SBA lending stable is structural, not emotional. The guarantee mechanism lowers lender exposure without eliminating discipline. Banks still underwrite real businesses with real cash flow. The SBA simply absorbs a portion of the downside risk, which allows capital to move when it otherwise would not. Stability comes not from avoiding risk, but from distributing it intelligently. That distinction matters in an era defined by asymmetry. Capital markets now reward scale, speed and technological leverage. Small businesses do not compete on those terms. They compete on durability, local knowledge and long-term horizons. SBA programs align with those realities by offering longer terms, predictable pricing and financing structures that match how small businesses actually operate. The current macro environment only reinforces this role. A weaker dollar raises input costs and pressures margins. Tariffs and supply chain realignments force operational changes. Labor dynamics continue to shift. These are not reasons to stop investing. They are reasons to invest with patience and structure. SBA lending provides both. For lenders, SBA loans create portfolio balance during volatile cycles. Guarantees reduce loss severity. Secondary market liquidity supports capital efficiency. Fee income adds consistency when traditional commercial pipelines slow. This is not theoretical. In past downturns, regions with active SBA lending recovered faster, maintained higher employment and preserved more small businesses through the cycle. CONFIDENCE IN THE PROGRAM Why SBA Lending Holds Steady When the World Does Not 8 | INDEPENDENT REPORT
For borrowers, SBA lending offers breathing room. Longer amortizations lower the monthly pressure. Working capital and refinance options stabilize balance sheets. Access to capital during uncertain periods allows owners to focus on operations rather than survival. That space is often the difference between endurance and failure. Confidence in a program does not come from slogans or headlines. It comes from repetition. From watching a system perform its function across different political administrations, regulatory climates and economic regimes. SBA lending has done that work quietly for decades. At B:Side Capital, our confidence in the SBA is not abstract. It is earned through cycles. Through deals completed when sentiment was negative and liquidity was tight. Through partnerships with banks who understand that serving small businesses is not about timing the cycle but staying in the game long enough to matter. We are not blind to the noise. We simply refuse to let it dictate our posture. Crisis eras reward institutions that stay disciplined, boring and consistent while others chase novelty or freeze in fear. SBA lending is not flashy. It does not promise shortcuts. It offers structure, patience and continuity. In times like these, that is not a weakness. It is an advantage. Confidence in a program does not come from slogans or headlines. It comes from repetition. INDEPENDENT REPORT | 9
Industrial Loan Bank Charters The Footnote Penciling in Its Own Chapter By John Podvin, Partner, and Jenny Small, Partner Otteson Shapiro, ICBC Silver Associate Member What had long been a controversial footnote in discussions of bank chartering options is now, within just a few months, touching a nerve in the banking industry by providing new material for its own chapter on bank chartering and structuring. Its renaissance comes at a time when DeFi companies and others are looking to enter the regulated banking fold, catalyzing federal and state bank regulators to recalibrate bank structure. For digital asset banks and others, the question is no longer simply whether to form a bank or buy one, but instead how to find the Goldilocks charter that is just right for a proposed bank’s business model. Proposed banks with business models focused on the custody and fiduciary activities of digital assets can opt for a national trust bank charter, as many have. But hot on the heels of the OCC’s rebranding of its chartering function, Interpretive Letter 1188, and the conditional approvals of six digital asset national banks in 2025, a “notorious” state chartering option has emerged for proposed banks seeking more reliable funding. For this reason, Ford, GM, PayPal and Affirm, distinct business concepts often not spoken of in the same breath, are all trying to access banking to use deposits to fund their credit products. Without a bank, companies like Ford, GM, PayPal and Affirm fund their credit products through capital markets, warehouse lines, securitization and other means. On Jan. 22, 2026, Utah approved industrial loan bank (ILB) charters for Ford Credit Bank and GM Financial Bank. Meanwhile, in December 2025 and January 2026, PayPal and Affirm submitted applications to Utah and Nevada state agencies, respectively, for ILB charters. All four companies are looking to avail themselves of deposits for more reliable, cheaper funding and, in turn, survive in this fiercely competitive economy through scalability. While a traditional bank charter would offer the same funding advantage, any company that owns a bank is generally deemed a bank holding company and is governed by the Bank Holding Company Act (BHCA). The BHCA imposes very constraining restrictions, including limitations on engaging in activities unrelated to banking. In other words, Ford would not be able to operate a bank under a traditional charter and continue manufacturing and selling cars (unless it could convince the Federal Reserve that manufacturing and selling cars are incidental to banking). ILBs, though, are a rare banking charter structure whose parent companies are exempt from the Bank Holding Company Act (BHCA) so long as they continue to meet certain regulatory requirements. That carve-out stems from the Competitive Equality in Banking Act of 1987 (CEBA). Today, six states authorize industrial loan banks: California, Hawaii, Indiana, Minnesota, Nevada and Utah (with Colorado having repealed its statute). An ILB may accept FDIC-insured deposits and, for most practical purposes, operates like a full-service bank, including the ability to branch and establish loan production offices across state lines. The charter, therefore, provides access to stable, insured funding and the credibility of the federal banking system. While the benefits of ILBs are clear, they have historically faced regulatory headwinds and are the subject of robust policy debate. On Aug. 1, 2006, the FDIC imposed a six-month moratorium on applications for deposit insurance for ILBs. This moratorium was extended in January 2007, and it was widely reported as a factor in Walmart’s withdrawal of its application for deposit insurance for an ILB it was attempting to charter at the time. The moratorium was later codified in Federal statutes for three years under Section 603 of the Dodd-Frank Act, which expired on July 21, 2013. Since that time, only a few ILBs have been successfully chartered, including Nelnet Bank, Square and Thrivent Bank. During the same period, the number of industrial loan banks declined. In 2021, the FDIC finalized regulations in 12 CFR Part 354 imposing written agreement requirements, commitments and operational restrictions for certain companies that control an ILB but are not subject to federal consolidated supervision by the Federal Reserve. At the same time, ILBs continue to face serious opposition, and the debate has never been more heated than it is today. Last fall, Sens. Elizabeth Warren and Andy Kim sent a letter to the FDIC urging Acting Chair Travis Hill to re-impose a moratorium on new deposit insurance applications submitted by ILBs. The Independent Community Bankers of America (ICBA) has consistently opposed ILB charters. In a November 2025 white paper, the ICBA argued that ILBs allow commercial and fintech firms to enjoy the benefits of federal deposit insurance and banking powers without being subject to the full scope of bank holding company regulation. In ICBA’s view, this creates competitive inequities and raises concerns about the separation of banking and commerce. But in today’s rate environment and the recalibration of bank charter structures, the policy debate faces a rising tide of demand for bank charters in all the flavors they come in. As a result, the ILB charter is no longer a mere footnote. Whether this resurgence lasts is less likely to depend on policy discussion and more likely to depend on execution, supervision, and the industry’s ability to demonstrate that the model can balance innovation with safety and soundness. 10 | INDEPENDENT REPORT
| Bank Stock Loans | Loan Participations | ATM/Debit | International Services | | Cash Management | Securities Safekeeping | Merchant Services | 800-873-4722 | NE: 888-467-5544 | www.bbwest.com Where community banks bank Est. 1980 – Over 45 years of service to community banks “Bankers' Bank of the West has been a steadfast supporter of the Independent Community Bankers of Colorado for over 30 years. ICBC’s dedicated advocacy ensures that community banks have the representation and resources they need. As the correspondent serving 95% of Colorado’s community banks, we are proud to champion that mission.” Across the western states and Great Plains, we’re the place where community banks bank. That’s because we provide the services, technology, and expertise to help you extend your resources, deliver for your customers, and stand out in your market. 5 reasons to partner with Bankers’ Bank of the West BBW - President and CEO - Bill Mitchell 1. Drive efficiency and savings through sophisticated, scalable solutions powered by our community-bank network. 5. Our priorities are aligned with yours. 2. You can expand your capabilities. 4. We’ll never compete for your customers. 3. You can count on prompt, reliable service. • Bankers’ Bank of the West is ready to support your transition. We offer international check processing, collections, currency services, and international wire transfers. Ensuring you stay fully operational before, during, and after the Fed’s phaseout. International Services $ 8.45B assets under management $ 1.9B daily transaction value processed/settled Serving more than 95% of community banks in: Colorado Debbie Wendt SVP & Chief Payments Officer Contact our Cash Management team today at ops@bbwest.com to learn how we can make your transition more efficient. • FedGlobal ACH to Mexico & Panama ends Nov. 20, 2026. The Fed will stop accepting forward items after this date. • Foreign & Canadian Check Services end Dec. 4, 2026. Forward items accepted only through this cutoff. • Institutions should transition now to avoid service gaps. The Fed urges early planning due to the full discontinuation by end-2026. IMPORTANT NOTICE! Discontinuation of FedGlobal® ACH Payments and the Foreign and Canadian Check Services
As the industry continues to evolve, community institutions find themselves at the intersection of innovation, regulation and resilience. From navigating macroeconomic uncertainties and headwinds to adapting to the rise of digital assets like stablecoins, institutions are confronting both challenges and opportunities that will shape their future and competitive edge. At the same time, regulatory relief efforts and shifts in executive compensation strategies reflect a broader transformation in how community banks operate and compete. We highlight some of the key items influencing the sector in 2026. STABLECOINS: A GROWING FORCE AND A LIQUIDITY RISK CHALLENGE Stablecoins — digital assets pegged to fiat currencies like the U.S. dollar or gold — are rapidly gaining traction as a medium of exchange and store of value. As market capitalization and institutional interest continue to grow, so does the likelihood of stablecoins becoming a mainstream financial instrument. At this point, legislation such as the GENIUS Act in the Senate and the STABLE Act in the House seeks to set the framework for stablecoins. If legislation doesn’t require stablecoin reserves to be held in banks, community institutions risk losing deposits to unregulated entities. Allowing nonbank issuers to operate without equivalent oversight invites regulatory arbitrage and potential fraud. COMMUNITY BANK REGULATORY RELIEF As part of a broader, multiphase initiative to modernize regulatory thresholds in light of inflation, regulatory leaders proposed an update to the Federal Deposit Insurance Corporation Improvement Act (FDICIA) in July 2025. This move is designed to modernize the legislation and provide a more durable and equitable regulatory framework, especially for community banks and mid-sized institutions that may otherwise cross compliance thresholds due to inflation rather than operational growth. The proposed changes had a comment period that ended in September 2025, and the final Navigating the Evolving Landscape of Community Banking By Ryan Abdoo and John Byczkowski Plante Moran, ICBC Silver Associate Member 12 | INDEPENDENT REPORT
rule was published in November 2025 with the following key components (among other things): • Independent financial statement audits are only required for institutions with over $1 billion in assets (increase from $500 million). • The establishment and composition of an audit committee. ° General Composition Requirements: The asset threshold for requiring an audit committee composed entirely of outside directors increased from $500 million to $1 billion. ° Independence Requirements: For institutions with assets between $1 billion and $5 billion, the audit committee must comprise a majority of outside directors who are independent of management. ° Enhanced Independence Requirements: For institutions with assets over $5 billion, the audit committee must comprise only outside directors who are independent of management. • Management assessment of internal control is required for institutions with over $1 billion in assets (an increase from $500 million). • A financial statement auditor opinion on internal control over financial reporting (ICFR) is required for institutions with assets over $5 billion (an increase from $1 billion). • The financial statement auditor would follow the more stringent independence standards of the Securities and Exchange Commission and Public Company Accounting Oversight Board when asset thresholds exceed $1 billion (an increase from $500 million). The rule is effective as of Jan. 1, 2026, but also provides that banks don’t have to comply with applicable part 363 requirements as of Dec. 31, 2025, if they won’t be subject to those requirements based on the updated thresholds in place as of Jan. 1, 2026. EXECUTIVE COMPENSATION: A SHIFT TOWARD STOCK-BASED ALTERNATIVES Community banks have increasingly moved away from traditional stock options in favor of alternative equity compensation structures such as restricted stock, restricted stock units (RSUs) and stock appreciation rights (SARs). This shift reflects a broader trend toward aligning executive incentives with long-term shareholder value while managing risk and complexity. RSUs have gained popularity due to their simplicity and guaranteed value upon vesting, unlike stock options, which can become worthless if the stock price falls below the strike price. SARs offer another flexible alternative, allowing executives to benefit from stock price appreciation without requiring upfront capital investment. This evolution in compensation strategy also reflects a desire to attract and retain top talent in a competitive labor market while ensuring that executive rewards are tied to sustainable performance and risk management. COMMUNITY BANK PERFORMANCE: RESILIENCE AMID HEADWINDS Despite macroeconomic pressures and uncertainties, community banks have demonstrated resilience. Capital ratios remain strong and, even though loan-to-deposit ratios have tightened due to the mix of loan demand and deposit competition, net interest income and net interest margin improved throughout 2025, approaching pre-pandemic averages. Past-due and nonaccrual rates have trended downward while reserve coverage ratios remain strong. Overall, the outlook appears cautiously optimistic. Scan the QR code for more insights from our trusted advisors. https://www.plantemoran.com/ industries/financial-services/banks?utm_ source=qrcode&utm_medium=association&utm_ campaign=PEN-FSG-2026_ICBC As the industry continues to evolve, community institutions find themselves at the intersection of innovation, regulation and resilience. INDEPENDENT REPORT | 13
Your website should be one of your strongest business tools. It’s often the first impression, the primary source of information and a key driver of leads and conversions. But if you’re seeing traffic drop, engagement decline or bounce rates climb, something isn’t working, and it’s likely costing you opportunities. The good news? Most website issues are common, identifiable and fixable. Here’s why visitors may be leaving your site and what you can do right now to turn things around: 1. YOUR WEBSITE IS TOO SLOW Speed matters more than ever. If your site takes more than a few seconds to load, visitors won’t wait; they’ll leave. Search engines also penalize slow sites, making it harder for new users to find you in the first place. That means if you are bidding for search terms, even your PPC efforts aren’t working to the best of their ability. How To Fix It Fast Code density, evaluating your caching technique and making sure your hosting solution can handle your traffic are small but mighty improvements. A performance audit can quickly uncover bottlenecks that are dragging your site down. 2. YOUR CONTENT ISN’T CLEAR OR RELEVANT Visitors come to your website with a specific question or need. If they can’t immediately understand what you do, who you serve or how you help, they won’t stick around. Outdated messaging or generic copy can be just as damaging. Also, think about specific keywords that your users are searching for and be sure to include those in your content. How To Fix It Fast Revisit your homepage and top landing pages. Make sure your value proposition is clear within seconds. Speak directly to your audience’s pain points and update content regularly to reflect current offerings, services, priorities and top search terms. 3. YOUR SITE ISN’T MOBILE-FRIENDLY A majority of users now browse on mobile devices. If your site isn’t optimized for smaller screens, slow connections or touch navigation, you’re likely losing visitors before they even engage. How To Fix It Fast Ensure your website uses responsive design and test it across devices. Buttons should be easy to tap, text should be readable without zooming, and navigation should be simple and intuitive. Almost all website designs can be adjusted for mobile-friendly views, but more often than not, you forget to check the mobile view. Why Your Website Is Losing Visitors — and How To Fix It Fast By Bella Ruscheinski, Solutions Project Manager Spry Inc., ICBC Associate Member 14 | INDEPENDENT REPORT
4. NAVIGATION IS CONFUSING OR OVERWHELMING Too many menu options, unclear labels or buried information can frustrate users quickly. If visitors can’t find what they’re looking for, they’ll leave and probably won’t come back. Avoid mega menus (a large multi-column dropdown menu) that can overwhelm and confuse your users on which option to choose, if possible. How To Fix It Fast Simplify your navigation. Focus on the pages users care about most and guide them clearly through your site. Clear calls-to-action and logical page flow make a significant difference in keeping visitors engaged. Remember to check the top search terms and most trafficked pages, and don’t leave those out. 5. YOUR WEBSITE LOOKS OUTDATED Design trends evolve, and so do user expectations. An outdated website can make your business appear less credible or less trustworthy — even if your products or services are top-notch. How To Fix It Fast A design refresh doesn’t always require a full rebuild. There are thousands of website templates that are simple to add to your site; it doesn’t all have to be custom code. A simple font, color, imagery or layout can go a longer way than you think. It can also improve user confidence in your company. Your website should attract the right audience, keep them engaged and guide them toward action. TURN YOUR WEBSITE INTO A GROWTH ENGINE Losing website visitors isn’t just a traffic problem — it’s a business problem. Your website should attract the right audience, keep them engaged and guide them toward action. At Spry, we help businesses identify what’s holding their websites back and implement smart, fast solutions that improve performance, user experience and results. Whether it’s a quick optimization or a strategic refresh, the right changes can make an immediate impact. INDEPENDENT REPORT | 15
Community banks are woven into the fabric of the communities they serve. Their success relies on strong relationships, local decision-making and a deep understanding of customer needs. Yet even the most community-minded bank must intentionally prepare for the future. Strategic planning has become one of the most essential leadership priorities, ensuring that the bank remains strong, competitive and aligned with its mission. A solid strategic plan creates clarity — clarity of vision, priorities and responsibilities. When teams understand where the bank is headed and why, they can make better decisions every day. The planning process aligns leadership and staff around a shared direction, reducing confusion and increasing accountability. It also helps ensure that resources such as technology investments, staff development and growth initiatives are focused on what matters most. Insight is another key outcome. Community banks possess invaluable firsthand knowledge about the people and businesses in their markets. Strategic planning structures that insight into meaningful decisions. It invites leaders to examine local demographics, identify emerging opportunities and strengthen the bank’s competitive positioning. When done well, the plan becomes a practical blueprint that connects the bank’s strengths — trust, expertise and relationships — to the evolving financial needs of its customers. One often overlooked benefit is the impact on workforce engagement. Employees feel more connected and motivated when they understand how their contributions support the bank’s goals. According to Gallup, organizations with higher employee engagement experience better customer loyalty and stronger business outcomes. Strategic planning sets the tone for a culture where employees are empowered to contribute ideas and deliver exceptional service. Bringing in an outside firm to facilitate the process can provide tremendous value. External experts create a safe environment for open, honest discussion. They help leadership teams ask the right questions, challenge assumptions and ensure all perspectives are heard. Their objective viewpoint can reveal blind spots and spark innovation. Additionally, a skilled facilitator keeps the planning sessions focused, efficient and action-oriented — preventing the process from becoming a routine checklist exercise. Ultimately, strategic planning is a commitment to the future strength of the bank and the community it serves. With a clear roadmap and the right partners at the table, community banks are better equipped to grow, navigate uncertainty and remain the trusted financial cornerstone their customers depend on. Community banks are more than financial institutions; they are community builders. Throughout 2026, let’s continue to embrace this identity and take bold steps forward. Whether through deepened local impact, thoughtful innovation or team empowerment, the work we do today will set the foundation for stronger, more vibrant communities tomorrow. For help with strategic planning, contact Connie West at The James Paul Group at cwest@jamespaulgroup.com or toll-free at (877) 584-6468. The Importance of Strategic Planning For Success in 2026 and Beyond By Connie West, Gallup Certified Strengths Coach, Regional Vice President The James Paul Group, ICBC Associate Member 16 | INDEPENDENT REPORT
For decades, many community banks have taken a passive approach to investments, primarily using the portfolio as a place to park liquidity and earn spread income, but not always as a tool in dynamic balance sheet management. This approach worked efficiently over many years of relatively stable interest rate cycles, which produced modest unrealized gains and losses. However, the past few years have shown that interest rate cycles can be anything but stable. In just the last three years, the yield curve whipsawed from steep to deeply inverted and back again in record time. Funding costs spiked, deposit behavior shifted, and liquidity pressures intensified. The pace of change has undoubtedly accelerated, and the rate environment may well transform again over the next 12-18 months. In this era of heightened volatility, the “set it and forget it” strategy can leave valuable opportunities — and necessary risk adjustments — on the table. To be clear, strategic portfolio management does not mean actively trading bonds. For community banks, it simply means making intentional, timely adjustments to align the investment portfolio with evolving interest rate, liquidity and balance sheet needs. WHERE PASSIVE PORTFOLIO MANAGEMENT FALLS SHORT There is nothing inherently wrong with buying bonds and holding them to maturity. Doing so minimizes earnings volatility and the operational resources needed to manage the portfolio. It aligns with the inherently conservative nature of community banks and draws little extra attention from examiners. But the drawbacks become clear when the rate environment changes dramatically, especially when it does so as quickly as it has this cycle. Since the rapid rate run-up of 2022-2023, the investment portfolio has come into sharper focus. Historic unrealized losses combined with liquidity pressures in early 2023 exposed the risks of holding significant underwater assets and forced many institutions to confront the challenges of selling assets at steep losses. In the wake of such volatility, regulators have encouraged institutions to view the portfolio as a central element of asset-liability management, and prudent portfolio actions can be considered part of a holistic balance sheet strategy. Although strategically managing the portfolio may mean taking the occasional loss on an underperforming asset, it can also mean locking in stronger earnings potential and better balance-sheet positioning for years to come. In aiming to avoid losses, institutions are effectively choosing to continue incurring a loss each day in the form of forgone income. Instead, strategically reallocating an underperforming asset into a better-performing one can lock in additional earnings power each day forward. When interest rates are changing dramatically, this more active approach can offer institutions greater flexibility to protect earnings, manage risk and seize opportunities as conditions change. MORE “ACTIVE MANAGEMENT” DOES NOT MEAN “ACTIVE TRADING” Active management is not about regular turnover; it is about making strategic adjustments. There are many simple tactics that can make meaningful improvements to portfolio performance. These include opportunistic sales of underperforming securities when market conditions improve their pricing, shifting a portion of the portfolio into a sector that offers better relative value, and executing bond swaps to better align the portfolio with asset-liability objectives. Even modest recalibrations can improve earnings and reduce risk without overhauling the portfolio. These moves do not require frequent trading but rather represent deliberate actions to keep the portfolio aligned with broader balance sheet objectives as the rate environment changes. A MORE BALANCED APPROACH For community banks, it is key not to abandon a buy-and-hold approach but to layer in a more flexible strategy. Maintaining a core portfolio of long-term holdings while selectively repositioning at the margins preserves stability and positions institutions to respond as conditions change. The goal is simply to assess which securities no longer align with strategic goals and identify where modest portfolio adjustments can pay dividends. In this new era where interest rates and funding dynamics can change dramatically in a matter of months, prudent portfolio management requires considering occasional strategic adjustments, not through frequent trading but through thoughtful, deliberate actions that keep the investment portfolio optimized even as conditions change. Andrea F. Pringle is a financial strategist and MBS analyst at The Baker Group. A native Oklahoman, she began her career in Washington, D.C., where she earned her MBA from George Washington University. Andrea worked on the capital markets sales and trading desk at Fannie Mae for five years before returning to Oklahoma to work in corporate finance. Before joining The Baker Group, Andrea served as a corporate finance supervisor at a publicly traded energy company. She joined The Baker Group in 2020 with a special focus on mortgage products and investment strategies. Moving Beyond ‘Set It and Forget It’ Elevating Portfolio Management From Passive To Purposeful By Andrea Pringle, Financial Strategist, MBS Analyst The Baker Group LP, ICBC Associate Member INDEPENDENT REPORT | 17
While generative AI headlines often dominate the conversation, financial institutions are increasingly investing in more practical applications: integrated smart features that support day-to-day operations. Artificial intelligence built into existing systems can help reduce manual workloads and support compliance in a data-rich environment that is becoming increasingly complex. At Alogent, this is the foundation of our AI strategy: solution features designed with intention, tested in real-world conditions and deployed where they deliver the most value. In a recent conversation with Monica Moore, Alogent’s chief technology officer, we discussed how this philosophy has shaped our innovation efforts, especially in the development of FASTdocs’ AI-powered document classification capabilities. INNOVATION GROUNDED IN PURPOSE “Innovation doesn’t have to mean inventing something from scratch,” Moore said. “It means creating a solution that either didn’t exist before or solving an existing problem in a more effective or valuable way.” Manual indexing is time-consuming and error-prone, especially for image-based documents such as scanned receipts, handwritten forms or faxed contracts. After listening to customer feedback and identifying a clear market gap, Alogent developed an AI-enabled document classification tool within FASTdocs to automate the process. The goal was to solve a familiar challenge faster, with greater precision and scalability. From ideation to production, the feature was built in just nine months. According to Moore, that speed was made possible by a focused approach: “AI allows us to move faster without compromising on the rigor of our processes. We relied heavily on user groups, focus sessions and proof-of-concept testing to make sure what we built mapped directly to customer workflows.” PRACTICAL AI, BUILT FOR FLEXIBILITY FASTdocs’ classification feature is designed with adaptability in mind. It leverages large language models (LLMs) to automatically identify and categorize both text- and image-based documents, extracting key metadata such as account numbers, dates and amounts along the way. “AI is a new power tool,” Moore added, “especially in financial services, where compliance and security are non-negotiable. Our job is to ensure innovation and responsibility coexist.” By automating document sorting and indexing, institutions can: • Reduce manual errors and improve data accuracy • Standardize document structures across systems • Simplify regulatory oversight and strengthen governance • Free staff for higher-value tasks like account holder engagement and strategic planning WHERE INNOVATION MEETS EXECUTION With FASTdocs as a cornerstone of Alogent’s ECM Suite, financial institutions can see how intelligent automation transforms operations without adding complexity. From enterprise content and loan management to deposit automation and check fraud mitigation, Alogent delivers end-to-end solutions that power every part of the financial ecosystem, helping institutions scale efficiently and lead with confidence. To talk to Team Alogent about how we can help you move forward with confidence, call (888) 332-7052 or visit www.alogent.com/contact. Driving Innovation With AI Empowering Financial Institutions With AI-Powered Document Classification By Alogent ICBC Associate Member 18 | INDEPENDENT REPORT
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