SUMMER 2025 2025 MIB Convention & Trade Show ROUND UP
SAVE the DATE 2025 MIB Women in Banking CONFERENCE October 8-9 SPRINGHILL SUITES BOZEMAN This exciting event is designed to inspire, motivate and empower women working from all areas of the bank. mibonline.org
26 23 7 2 SAVE THE DATE 2025 MIB Women in Banking Conference 4 PRESIDENT’S MESSAGE Mentorship and Connection By Loren Brown, President, MIB 7 EXECUTIVE DIRECTOR’S MESSAGE Honored to Serve as the New Executive Director of MIB By Shane Scanlon, Executive Director, MIB 10 FLOURISH Conversations Must Determine Our Innovation Budgets By Rebeca Romero Rainey, President and CEO, ICBA 11 FROM THE TOP Turning Vendors Into Partners With ICBA By Jack E. Hopkins, Chairman, ICBA 12 Part 1: Beyond the Bonus How to Attract Long‑Term Account Holders By ADVANTAGE 13 SAVE THE DATE University of Montana Tailgate 14 Compliance Q&A By Bill Showalter, Senior Consultant, Young & Associates Inc. 18 FRAUD WATCH How To Prevent Wire Fraud By Scott Anchin, Senior Vice President of Strategic Initiatives and Policy, ICBA 20 Tom Keenan of Keenan & Partners MIB’s 2025 Outstanding Associate Member 23 Part 2: From Transactions to Trust Deepening Account Holder Relationships By ADVANTAGE 26 2025 MIB Convention & Trade Show Round Up 28 2025 MIB Membership Directory 28 MIB Associate Member Banks 29 MIB Associate Member Resource Guide 30 MIB Upcoming Events 31 Bank Training Webinars Contents SUMMER 2025 2025 MIB EXECUTIVE OFFICERS Loren Brown, President Ascent Bank, Helena lbrown@ascentbank.com Amber Brown, Vice President Peoples Bank of Deer Lodge abrown@pbdl.net Clinton Gerst, Secretary Bank of Bozeman cgerst@bankofbozeman.com Laura Clark, Treasurer Opportunity Bank lclark@oppbank.com Tim Schreiber, Immediate Past President Farmers State Bank tims@farmersebank.com Kenny Martin, ICBA State Director Independence Bank, Helena kennym@ibyourbank.com 2025 MIB BOARD OF DIRECTORS Tom Christnacht First Security Bank of Deer Lodge Bill Coffee Stockman Bank, Miles City Daniel Day Bank of Montana, Missoula Shawn Dutton First Security Bank of Roundup Mike Hawthorne First Montana Bank, Missoula Logan Hensley Valley Bank of Kalispell Brice Kluth First State Bank of Shelby Scott Mizner American Bank, Bozeman Joel Rosenberg Three Rivers Bank of Montana, Kalispell Andrew West Eagle Bank, Polson Phil Willett Pioneer Federal Savings and Loan, Dillon ASSOCIATE BOARD MEMBER Ryan Fritz Citizens Alliance Bank rfritz@citizensalliancebank.com MIB STAFF Shane Scanlon, Executive Director Montana Independent Bankers shane.d.scanlon@gmail.com ©2025 The Montana Independent Bankers Association (MIB) | The newsLINK Group LLC. All rights reserved. Community Banker is published four times per year by The newsLINK Group LLC for MIB 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 MIB, 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. Community Banker is a collective work, and as such, some articles are submitted by authors who are independent of MIB. 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. MONTANA INDEPENDENT BANKERS 1812 11th Ave. PO Box 4893 Helena, MT 59604 (406) 449-7444 shane.d.scanlon@gmail.com mibonline.org Community Banker 3
PRESIDENT’S MESSAGE MENTORSHIP AND CONNECTION BY LOREN BROWN PRESIDENT, MIB Hello my friends, I hope you all have enjoyed this fabulous Montana summer! By the time you read this, the weather may have changed, but I am writing it at the end of July after enjoying some of the best Montana weather I can remember for a summer. Thank you to all of you who joined us for our 2025 Montana Independent Bankers Convention and Trade Show held at Big Sky Resort. We had outstanding attendance this year. And speaking of weather, we couldn’t have asked for better weather for the three days. Probably the only complaint was that we had to have the classes and meetings inside rather than outside, enjoying Big Sky’s weather and beauty! I heard nothing but fun and enjoyment was had on the rafting trip, the golfing event and from folks who just got out, hiked and explored the mountain and surrounding area. We had excellent sessions put on by a variety of topic experts. Everyone had a fabulous time interacting with each other at our PAC auction, gala, receptions, meals and other fun events. If you were there, you know what a valuable experience it was. If you missed it, I am sorry and I hope you will make it a point to join us next year! An absolutely bittersweet moment for me during the convention gala was getting to recognize our outgoing executive director, Jim Brown. As I have shared in previous articles, Jim and I have absolutely no family relationship despite our shared last name. However, when I joined the board of the MIB in 2017, Jim welcomed me with open arms as if I were a family member, just like he has done for the other new board members I have seen join our organization’s leadership team. Jim was incredibly passionate about the MIB’s mission and purpose and shared that with me. He helped show me the ropes and explained what was expected of a board member and how I could be most effective for the organization and for the community banks in our state. Jim also encouraged me to attend my first ICBA LIVE, which was an absolutely eye-opening experience. I haven’t missed one since. Jim also encouraged me to 4 Community Banker
attend my first-ever ICBA Capital Summit to interact with our elected officials in Washington, D.C., and share with them the importance of community banking. I was incredibly nervous about meeting with our congressional delegates and knowing what to say. Still, Jim supported me and the other Montana attendees and ensured our voices were heard in D.C. Today, I feel very comfortable and confident in sitting down with our representatives and senators, both at the state and federal levels, thanks to all the mentorship Jim gave me. When I was asked to become an officer of the MIB, Jim once again stepped up and explained to me what my duties would look like and helped guide me through fulfilling those duties. And finally, as I stepped into the role of president of the Montana Independent Bankers, he was again right there by my side, helping ensure I was set up for success! Even writing these letters is one of the many things that Jim has helped coach me in and support me over the past year. (He didn’t help write this one or know what I was writing about.) As a leader of a community bank, I know how important community banks are to my hometown, our state and our country, but I think Jim understands that role of our banks even better. I am sad to see Jim go as our executive director, but I am so excited for him and proud of him as he moves to the next chapter of his life. I know, even though he won’t be serving in the role of executive director, he will still be one of the biggest supporters of community banking in the country and in our great state. Thank you, Jim, for everything you have done for me and the Montana Independent Bankers! I am also super excited to welcome Shane Scanlon as our new executive director! Shane has a fabulous background in helping get things done with state and federal politicians. He is incredibly organized and will help lead the MIB through continued success as we continue to champion community banking. As we head into fall, we have more opportunities for all of our community bankers to continue networking and growing their knowledge through MIB offerings. I would encourage all our female readers to attend the Women in Banking Conference that will be held Oct. 8-9 at the Springhill Suites in Bozeman. We get nothing but rave reviews on this event every year! As always, if there is anything I can do to better serve you please don’t hesitate to reach out. I am thankful for all of my fellow community bankers and community bank supporters! Community Banker 5
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EXECUTIVE DIRECTOR’S MESSAGE HONORED TO SERVE AS THE NEW EXECUTIVE DIRECTOR OF MIB BY SHANE SCANLON EXECUTIVE DIRECTOR, MIB I’m honored to have the opportunity to serve as the next executive director of MIB. It’s a tremendous privilege and responsibility, and I’m looking forward to the new role and the opportunities it will provide. Yes, there are big shoes to fill with Jim Brown retiring after 13 years of service, but he has passed on much insight and wisdom, and I will continue to lead the association with all that I have learned from him. On behalf of MIB, we are immensely thankful for Jim’s many years of service and the dedication he brought to the association. Jim is a natural-born leader, and we can’t thank him enough for his hard work in building up this successful association. Thank you, Jim! My journey with MIB actually began earlier this year when I handled their legislative portfolio during the 2025 legislative session that ran from January through April 2025. Those four months were fast-paced and vigorous as we digested bills that were beneficial, harmful and a few that would bring unintended consequences to our community banks. Every step of the way was a learning opportunity, getting feedback from board members about the implications and finding the best ways to educate legislators on the importance of supporting and protecting our community banks across the state. I was very pleased to see the strong support our community banks have from legislators from both sides of the aisle. It speaks to the trust and credibility each of your banks brings to your local community. From updating Montana’s banking laws to clarify that an ITM does not qualify as a branch following the FDIC’s ruling in Q3 of 2024, and important housekeeping and efficiency changes to the Uniform Unclaimed Property Act, to allowing vehicle transfers without a notary — just to name a few successes — we were part of a team that brought improvements to our banks. It was also timely that being selected to serve as the executive director would lead right into the celebration of MIB’s 58th Annual State Convention! The three-day convention brought educational and networking opportunities for our members, and for me, many introductions to new faces. When I heard this convention was the “biggest little banking convention in the West,” that was an understatement. With record attendance, Community Banker 7
everyone in that room saw the value of bringing bankers together to reconnect, engage and recognize the value and impact our community banks bring to the state. The speakers that attended were phenomenal. We can’t thank each of them enough for taking time out of their schedule to be at our Convention. A few notable mentions include: • Mike Burke, vice chairman of the Independent Community Banks of America, delivered the main speech at the Gala. • Angie Murdo, principal at Pinion, provided a Director’s Training. • Jeffrey Michael, director of the Bureau of Business and Economic Research at the University of Montana, gave a 2025 Mid-Year Economic Outlook for Montana and the U.S. • Tom Kennan, president of Keenan & Partners, discussed whole bank valuation in the current market environment. • Robert Finch, managing director at Stifel, gave an overview of the operating environment, ecosystem and forward-looking appointees for community banks. • Melanie Hall, commissioner of the Division of Banking and Financial Institutions for Montana, presented the latest developments in her office and provided a recap of the legislative session. Finally, I want to provide a little more background and share my Montana story. At the end of January/early February of 2014, I drove out to Montana from the East Coast, and of course, arrived in Bozeman with a snowstorm. After getting situated, I did what any new arrival would do, I headed to Bridger Bowl and skied on real snow after years of learning how to ski (survive) on ice. It was an incredible experience, and I remember leaving the ski hill knowing that this was going to be home. That would kick off the ongoing Montana adventure I’ve been on for the last 11 years, and lead to active senior roles in political campaigns, as well as work in government affairs and public relations. Most recently, I served as the campaign manager for the successful election of Tim Sheehy to the U.S. Senate in 2024, in what was the most highly contested U.S. Senate race in the nation that election cycle — and I think we’re all glad to be done with those political ads! I was also honored to manage U.S. Senator Steve Daines’s successful re-election campaign in 2020. I reside in Bozeman with my wife and three kids, a recently turned one-year-old son, a three-year-old daughter and a six-year-old son. Needless to say, we’re in the trenches, but we’re all having a blast! And, now, I look forward to this new journey serving as the executive director of MIB. Our Mission is to Help You Succeed Partner with us for: • Loan participation purchases and sales* • Bank stock financing • Bank executive and employee financing Craig McCandless SVP/Correspondent Banking Business Development Officer Based out of Billings, Mont. Covers: Montana, Wyoming and Idaho 406.850.3790 *We do not reparticipate loans. 8 Community Banker
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CONVERSATIONS MUST DETERMINE OUR INNOVATION BUDGETS FLOUR I SH BY REBECA ROMERO RAINEY PRESIDENT AND CEO, ICBA Innovation is one of those line items that can be hard to wrap our heads around. There’s no formula or silver bullet to determine how much to spend, so we annually face that Goldilocks conundrum of determining what’s too little, what’s too much and what’s just right. Yet, when faced with that uncertainty, I’ve found that dialogue can be the answer. Conversations with our leadership teams, full staff and customers will spark ideas that can help us focus on our true needs and evaluate our priorities. Those discussions start with determining how we define return on investment (ROI). With innovation, ROI is about looking through the lens of overall impact, not just how it will affect us financially in the year ahead. Ultimately, budgeting for innovation requires us to reverse-engineer our thinking and consider the price of not acting. We can’t just look at the fees for the technology or the integration; we also need to evaluate the cost of maintaining the status quo. That will help make the innovation investment more concrete and guide our decision-making. We need to identify a particular pain point, evaluate what it currently costs us in terms of staff time, customer attrition or other relevant variables, consider what may shift in the future and evaluate both the short- and long-term impact. That analysis helps us gain the concrete awareness needed to make informed decisions. And sometimes not acting is the right choice. Not every solution is going to work for everybody, but thoughtful conversations result in a conscious, strategic decision versus one informed by a reaction to a product price tag. This dialogue is critical to creating an innovation-centric culture that is more about the process than the product. Brainstorming with our teams leads to valuable decision-making, and the ROI comes from the time we spend discussing and taking a proactive approach to problem-solving. Innovation is a journey, not a destination. It’s about enabling a mindset and culture that’s open to considering something different and continuing to shift with the needs of our customers and communities. As the financial services industry continues to evolve, we will increasingly face the challenge of balancing investment in innovation against budgetary constraints. Thoughtful discussions with our teams will shed light on the best approach for our individual banks. In these discussions, we will chart a course that’s right for our organizations, one investment at a time. 10 Community Banker
TURNING VENDORS INTO PARTNERS WITH ICBA FROM THE TOP BY JACK E. HOPKINS CHAIRMAN, ICBA We’ve all been there: We identify a technological or operational need in our banks, and the work to find a provider begins. That effort extends far beyond identifying a fitting, affordable solution. We also seek out a vendor who provides a real relationship and the same level of service we offer our customers. And that’s where we may find trouble. Vendors abound, but true partners are few and far between. Yet, ICBA offers the path to finding the right fit. With ICBA Preferred Service Providers and the Corporate Member Directory, the legwork to narrow the field is already done. If ICBA has included a vendor, we know they are a source that can be trusted and one that truly “gets” community banks. For instance, when my bank was seeking a new operating system, we used ICBA as a primary source of potential partners. We came back from ICBA LIVE with a shortlist of eight to nine different firms, researched them more extensively through the Corporate Member Directory and selected five for interviews. As far as due diligence, having access to these providers at LIVE and in the directory saved a ton of time because we knew they already had been vetted on the front end and were legitimate companies with experience working with community banks. We also include input from other community bankers as part of our process. When we know a colleague has used a particular vendor, we reach out to hear firsthand about their experience, and now the ICBA community has become another source of information. Increasingly, discussions about solutions and vendors are popping up, particularly relating to fraud monitoring and detection as we strive to address new and emerging threats. In my experience, engaging ICBA Preferred Service Providers and Corporate Members leads to a deeper relationship. They know relationships are our priority, and they make it theirs as well. They strive to build connections, customizing their solutions to our individual operational flows and addressing our unique needs. In that process, they shift from solution providers to partners. This demonstrates exactly how ICBA supports us. Whether we look at emerging solutions coming out of our ThinkTECH programs, learn about new technologies as part of our education programs or identify a vendor through the directory, ICBA offers tangible ways to help our banks across advocacy, education and innovation. In short, ICBA makes sure we have what we need and our voices are heard. In my mind, that is the definition of a true partner. MY TOP 3 Summer activities: 1. Spending time at the lake. 2. Getting out on bikes. 3. Doing any activity where you get to be outside. Community Banker 11
BEYOND THE BONUS In the race to grow deposits and market share, many financial institutions rely on cash sign-up bonuses to capture attention. While these offers can create a quick uptick in new accounts, they often fall short of delivering long-term value. For community institutions, trying to match the big-dollar offers of national brands can be costly — and risky. It’s worth asking: Are these incentives drawing loyal account holders, or simply “bonus chasers” who leave when a better deal comes along? THE PROBLEM WITH CASH BONUSES Cash bonuses may drive short-term results, but they rarely translate into meaningful relationships. New account holders drawn by a $200 or $300 offer often don’t set up direct deposit, use additional services or treat the account as their primary financial hub. The result? High acquisition costs, low engagement and disappointing ROI. Without a plan to encourage deeper connections, many of these accounts go dormant — or close entirely — after the initial reward is paid out. That’s why the key is to put a comprehensive strategy in place to achieve your goals. SMARTER INCENTIVES BUILD STRONGER RELATIONSHIPS A better approach focuses on encouraging regular usage and long-term engagement. Relationship-based incentives — such as cashback debit rewards or automatic round-up savings — are especially attractive to younger generations looking for digital convenience and long-term value. These tools not only provide ongoing value but also help establish healthier financial habits — making it more likely that consumers will stay. Add financial wellness features HOW TO ATTRACT LONG‑TERM ACCOUNT HOLDERS BY ADVANTAGE PART 1: 12 Community Banker
like budgeting apps, early direct deposit or credit monitoring, and your institution will begin to feel more like a financial partner than a promotional stopgap. Even simple touches — like custom alerts, personalized messaging or referral rewards — can make a lasting impression when they’re part of a larger strategy centered on helping account holders reach their goals. MOVE FROM ACCOUNT OPENINGS TO ACCOUNT RELATIONSHIPS Features encouraging routine activity — like direct deposit and automatic savings — signal a deeper relationship. These programs reduce dormancy and set the stage for long-term loyalty. Delivering real utility instead of one-time excitement builds trust — and trust is what turns a new account into a primary relationship. Not sure if your acquisition strategy is building long-term value? Scan the QR code for a free market assessment. https://info.advantage-fi.com/ contact-us-accountacquisition-inquiry Read Part 2 on page 23 to learn how personalization and community values deepen connections and keep account holders engaged for the long haul. ADVANTAGE is a trusted consulting partner for community financial institutions across the nation. We deliver consumer‑focused overdraft solutions, compliance expertise, account acquisition strategies and technology consulting to help institutions strengthen revenue, reduce risk and grow market share. Learn more at advantage-fi.com. Community Banker 13
COMPLIANCE BY BILL SHOWALTER SENIOR CONSULTANT, YOUNG & ASSOCIATES INC. TILA. Q: If the borrower shops for a title company, does the title closing/settlement fee still go into the annual percentage rate (APR) and finance charge calculations? The title company has a much higher fee than we normally encounter, which is raising the APR. A: A fee for conducting the closing/settlement is always a finance charge, no matter who imposes the fee and no matter whether the borrower shopped for the title company that is charging this higher fee. And since the borrower was shopping for a title company, it sounds like the bank requires the use of a title company and the closing/settlement service/event, which satisfies the “third-party test” you mentioned (in 12 CFR 1026.4(a)). So, put it in the finance charge and take it into account in your APR calculation. ECOA. Q: The bank has recently implemented an online application for secured consumer loans. We received an application from a borrower who lives in Pennsylvania, but we are located in Illinois. We are in the process of putting a hard stop in place in the online application program to not allow online applications for applicants outside of our bordering states. We tried to reach the applicant by phone and email to confirm that they intended to apply with our bank, but have not received a response. I do not want to send a notice of incomplete application (no income documentation provided) when we know that we would not approve a loan outside of our lending area, even if additional information is provided. I do not find that any of the standard denial reasons fit this scenario. We have not used “Other” in the past, but would it be acceptable to choose “Other” and enter “Applicant resides outside of lender’s lending area”? A: Yes, that would be perfectly acceptable. I am sure you have heard the general rule to stay away from the “other” reason — unless nothing else fits. Well, in this case, none of the other reasons fit (though, I believe some lenders will use the “we do not make that type of credit” (outside our area) reason. Your approach seems more informative to the applicant (which is the point of the adverse action notice process) than the “we do not …” approach. EFTA. Q: I am looking through Regulation E for information on periodic statements. Specifically, I am looking for support from the regulation that the bank must ensure that the customer is able to receive their statement. Our management suggested that we start charging customers a fee to mail their statements. If the customer Q & A 14 Community Banker
does not want to incur the fee, then we would hold their statement for pickup for 30 days. After 30 days, we would destroy their statement. Does this violate Regulation E requirements? A: The general rule in Regulation E is that the bank must “send a periodic statement for each monthly cycle in which an electronic fund transfer has occurred; and shall send a periodic statement at least quarterly if no transfer has occurred.” Holding statements for pick up is something that the bank may permit — but only at the customer’s request. It may not require that customers come in to pick up their statements. The requirement is to send the statements to customers. One other exception provides that a financial institution need not send statements to consumers whose accounts are inactive as defined by the institution. I have only seen fees for printed and mailed statements as an alternative to electronic statements. If the customer does not want e-statements, then they are charged a fee to cover printing and mailing costs for a physical statement. So, in either case, a statement is sent — a free e-statement or a fee-charged hard copy statement. TISA. Q: Our bank wants to send the following change in the terms message on statements: Important Notice: Previously, the tiers associated with your checking and savings accounts remained unchanged; however, they are now subject to change. Additionally, for accounts that do not currently have tiers, we reserve the right to introduce tiered structures in the future as part of our ongoing efforts to enhance our banking services. As a result, your Truth in Savings disclosure has been revised to reflect these changes. You can obtain a copy of the updated disclosure by visiting any of our financial centers, emailing us at ___@___.com or calling us at ___. If you have any questions or need further information, we’re happy to assist. We want to have the option to add tiers to products that are not tiered or adjust tiers to products in the future without any additional disclosure beyond the statement message below. The Truth-in-Savings disclosures would be updated to include language with the bank’s option to add or modify tiers. A: Whether the changes benefit the customers is not clear from the limited information we have been given here. If a tier(s) being added to an existing tiered product has higher interest rates than the existing tier structure, then that benefits the customer. If the bottom tier of a newly-added tiered structure equals the existing rate on the customer’s deposit product, with the remaining Community Banker 15
tiers at higher rates, then this again would seem to benefit the customer. But if any rates in any new tiering scheme are lower than the customers’ existing rates, then there is no benefit to the customer. If a change unequivocally benefits a customer for the remaining term of their account, then advance written notice is not required. Otherwise, notice must be sent at least 30 days before the change is effective. The bank should also consult with its legal counsel to determine if your state law allows such unilateral changes to deposit contracts, or if you need the customer’s agreement. Any change-in-terms notice, whether on/with a periodic statement (if all required language can be fitted in) or mailed separately, would need to fully disclose what the change consists of. The general language the bank proposes does not appear to fulfill the information requirements of Regulation DD for a change-in-terms notice. There are no account-specific details, which are required. This generic message could serve as some sort of early notice of potential upcoming changes, with more specific, TISA-compliant notices to come later when specific changes are made. ECOA. Q: Do the reasons on the adverse actions notice (AAN) for a loan applicant and the co-applicant need to be the same on the separate notices? May we list just the value or type of collateral not sufficient on the AAN for the co-applicant, or do we have to also show all of the reasons that the primary applicant is being denied? We received a loan application with a co-signer. We are denying the loan application for multiple reasons. The primary applicant has poor credit history, too high of a debt-to-income ratio and wants an unsecured loan. His AAN is straightforward. The issue is the AAN for the co-signer. He would be a good co-signer except he also wants the loan to be unsecured. The lack of collateral is the sole reason we are denying him. While we do make unsecured loans, such loans are generally for people we have a long history with and are for small dollar amounts. This loan is to be for $12,000, and the applicants have no history with us. A: No, the reasons for adverse action do not have to be identical on co-applicants’ AANs. The reasons may be identical since the Federal Reserve Board in the past basically said there should be no expectation of privacy among multiple applicants for credit. However, it is permitted to tailor the reasons disclosed for each applicant and put only the reason(s) that apply to that applicant on their individual AAN. EFAA. Q: The bank generally makes funds available the day after the deposit is made. When placing a large deposit check hold, I know that the first $275 must be available the day after the deposit, and the next $6,450 is subject to a two-day hold. Do we have to give a case-by-case hold notice for the two-day hold? If so, can we show both holds on the same notice? We would give the large deposit hold notice for the balance over $6,725. A: Yes, a case-by-case hold notice must be given if the bank wants to impose a two-day case-by-case hold on the bulk of the first $6,725 ($6,450). And, yes, the notice can be combined with the large deposit exception hold notice for the amount that exceeds $6,725. In fact, at least some of the forms companies (well, now software providers mostly) have a special combined form for large deposit holds — the case-by-case hold for the first part of the deposit and the exception hold for the excess amount, all on one form/notice. TILA. Q: We closed a TRID mortgage for a borrower four years ago on a horse farm/boarding/training facility with their personal residence. Now, the borrower would like a second loan to add on two buildings and expand the horse arena. I intend to place a junior lien on the real estate. This is a business-purpose loan, but since the first mortgage was done as a consumer loan under TRID, I am confused about how to do this second loan. Any guidance? A: The previous loan does not impact this subsequent loan. Lenders need to look at each loan transaction on its own. It sounds like the first mortgage must have been primarily for consumer purposes, so the bank followed TRID rules. But, if this current loan transaction is to be primarily for business/commercial/agricultural purposes, then it is exempt from Regulation Z — no TRID (or other TILA) disclosures or rescission required. Keep in mind, of course, the flood insurance rules and fair lending (nondiscrimination) requirements do still apply. Young & Associates provides banks and thrifts with support for their compliance programs, independent reviews and in‑bank training, as well as a full menu of management consulting, loan review, IT consulting and policy systems. 16 Community Banker
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With electronic payments becoming the norm, wire fraud is growing more common and varied in format. Wire fraud generally involves the use of electronic communication to defraud another person by phone, fax, telegram or, most commonly now, the internet. Notable scams to watch out for include romance scams on dating apps and social media; advance-fee scam emails promising rewards for financial help; phishing emails claiming account information has been compromised, with a link to input credentials; and hiring scams, where prospective “employers” request personal information like birth dates and Social Security numbers or a “processing fee.” Community banks must remain vigilant, as prosecutors or regulators may act against financial institutions that fail to recognize or prevent cases of wire fraud. FRAUD WATCH HOW TO PREVENT WIRE FRAUD BY SCOTT ANCHIN, SENIOR VICE PRESIDENT OF STRATEGIC INITIATIVES AND POLICY, ICBA 18 Community Banker
Banks can launch awareness campaigns to educate customers on avoiding scams. Encourage them to: • Use strong passwords and multifactor authentication. • Double check the identity of anyone requesting funds. For example, call a family member directly if “they” ask for financial help via social media before responding. • If the request is for an “urgent” transfer of funds, don’t rush to pay it. That is a red flag. • Avoid clicking on links. If you receive an email that appears to be from your bank, check the email address or go (separately) to the bank’s website to verify the request. • Watch for hiring scams offering unrealistically high salaries and complicated onboarding processes that involve requests for money. Banks can also work internally to protect customers from wire fraud by doing the following: • Have a clear plan for responding to suspected fraud, from freezing transactions to notifying law enforcement. • Train bank employees to spot red flags, like urgent requests for money and changes in vendor payment information. • Use multifactor authentication for access to financial systems. • Create clear wire transfer protocols within the bank. • When a wire transfer is requested, especially a new one, use multiple verification steps like multifactor authentication, callbacks or confirmation pop-ups. • Monitor real-time transactions using advanced algorithms and AI to flag suspicious patterns. • Look for — and flag — unusually large amounts being transferred or consider setting limits for wire amounts. • Look for transfers to countries at risk for financial fraud and money laundering. Refer to the Financial Action Task Force’s black and gray lists. • Require two individuals to verify high-value transfers. • Place holds on unusual transfers, allowing time for potential fraud to be caught. • Conduct regular internal audits to make sure the whole team is in compliance. Wire fraud is just one of many fraud and scam typologies. Community banks should integrate wire fraud education and internal controls into a comprehensive enterprise strategy. Proactive measures and ongoing vigilance can turn fraud prevention into a competitive advantage that builds lasting customer trust. Scott Anchin is senior vice president of strategic initiatives and policy for ICBA. Email Scott at scott.anchin@icba.org. Community Banker 19
TOM KEENAN of KEENAN & PARTNERS MIB’S 2025 OUTSTANDING ASSOCIATE MEMBER During last month’s convention, Tom Keenan was presented with MIB’s 2025 Outstanding Associate Member Award. As the owner of Keenan & Partners, Tom exemplifies everything it means to be a member of MIB. We recently had the opportunity to sit down with Tom and discuss his background, his career and learned more about what membership in MIB means to him. The following are excerpts from our conversation. Tell us about yourself. I grew up in a rural community in the state of Maryland. At the age of 10, I started working on local farms. I helped bring in the hay on horse and sheep farms, which eventually turned into full-time work on dairy farms during the summer months. That experience taught me a work ethic that I wouldn’t have learned elsewhere. I was sent away to boarding school during my high school years. From there, I went to the College of Wooster in Ohio. During my junior year of college, I had the opportunity to travel and experience the beauty of the American West. It was then that I knew I couldn't live on the East Coast. Straight out of college, I moved out west to Portland, Oregon, and I've been here ever since. I've been fortunate to have a career that allows me to travel throughout the West, including the great state of Montana. I've had three phases of my career. When I worked on farms, I helped build barns and fences, which led me to become a general construction contractor after college. I did that for the first 10-12 years of my career. I then moved into commercial real estate development throughout the western United States. I did that all the way up until the Great Recession in 2008, when my career changed immensely. There was no more development work because you couldn't find a bank loan to build any type of new building during that time. I was sitting on my hands for a month or two, wondering what I'd do next. That was when I received a higher calling. I had a lot of community banking relationships. I'd never owned a development firm, but I had arranged many construction, development and land acquisition loans as a borrower. A few months after the recession hit, I started getting calls from those same bankers I worked with, telling me they had a number of distressed projects — condominiums, apartment buildings and even some gas stations and retail stores — that were half built. The developers decided not to complete them because they knew there was no market to sell the finished product. These semi-completed projects were going to be mothballed. The bankers asked me if, with my construction background, I could tell them what the budget would be to complete that project, what the project was currently worth, what it would be worth at completion and if it was worth it to sell that non-performing loan to an investment group or somebody other than the bank. The end goal was to get that distressed asset off the books. Within six months, I had a full-time job advising community banks. I helped stave off failures. We figured out how to get bad assets out the door to clean up the books so banks could raise the additional capital they needed to weather that storm. It was an honor and a privilege to be able to help during that time. I did that until 2013. When we finally finished working and helping clients with that distressed asset book, my company boomed in a different direction. I had banks calling and saying, “We appreciate all the work you did with us in this real estate aspect, now we're going to look at repositioning our branch footprints. We want to open some branches; we want to close some branches. Can you help us establish 20 Community Banker
the value of this branch we've had for 80 years? If we were to close this branch location and sell it today, what is the branch worth? And if it's above our current net book value, can you help us to find a way to produce a yield on that to produce a gain on sale?” That turned into a whole new line of work that we're still doing today. And in that same vein, banks also call at times to ask: “Can you tell us what our deposits are worth? Can you tell us what our loans are worth? And what is our whole bank worth? And can you help us achieve the highest and best results with these items as well?” Being called on to assist with these generationally important items is an absolute honor. Through all the history I’ve described, I’ve had my wonderful wife with me. We’ve been married for 35 years now. We have two adult children and one grandson, and I’m really proud of both my kids and so lucky to have been married for all this time. What does this award recognition mean to you? When I first found out I’d be receiving this award, it took me by surprise. I was left speechless. This recognition means more than I can possibly express in words. I don’t typically seek awards, but the fact that the association saw fit to give me one for doing the things that we do every day leaves me with an immense sense of pride and appreciation for MIB and its entire membership. What has been the most rewarding part of your career? The most rewarding part has been the last 15 years, since founding Keenan & Partners in 2009 and helping community banks solve problems. Community banks are the backbone of our country, supplying 60% of the small business loans in the U.S. and 70% of all ag loans. I've always respected the community banking industry. It has built the prosperity of our nation and helping them is immensely gratifying. What is your greatest career accomplishment? My greatest accomplishment is starting my own company. It means I get to control the ethical decisions and how we treat our clients, and make sure decisions are made with integrity. How has MIB helped you throughout your career? What are the benefits of membership? I first became involved with MIB in 2018 when I was growing my business outside my home state of Oregon. At the very first convention I attended that year, I didn't know anybody. I was welcomed by the leadership, by the staff and most importantly, by the membership. The leadership found me immediately at the first night's reception and said, “Thank you for being a business partner. Let us introduce you to some of our banker members.” I don't get that treatment at a lot of state association conventions I attend, so their actions really stood out. The membership followed up with me afterwards and have always stayed in touch. I’ve been given active opportunities to participate in everything that MIB does. The benefit of membership is that you'll expand your horizons. They'll always make sure that you're invited to play a role, not just to attend an event. I’d like to add that Jim Brown has done a wonderful job. He'll be sorely missed, and I wish him all the luck in the next chapter of his career. Shane Scanlon is a great replacement; they couldn’t have done better in picking their next leader. I also want to mention that Marie Stark will be missed. She's been great to work with, and I wish her all the best in retirement. And working with Terri James is always a pleasure. What is the best advice you have ever received, and how has it been applied in your daily life? When I was at boarding school, it was a structured environment, which was very hard at times, but there were a lot of good things that came from the experience as well. The school gave us five words to live by: honor, integrity, respect, humility and excellence. And I've done my best to live by all five of those. I didn't really understand them well at 14 or 15 years old, but here I am at 60 years old, 45 years later, repeating them back to you. I try to remember all five of those every day — and I don't just mean at work. I mean in all aspects of my life and with other people, whether it be clients I'm doing business with, association staff and leaders who I may interact with, people I meet on the street or my own family. Trying to incorporate those five things into my daily routine has helped me succeed. Terri James, MIB Assistant, with Tom Keenan, Keenan & Partners Community Banker 21
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FROM TRANSACTIONS TO TRUST DEEPENING ACCOUNT HOLDER RELATIONSHIPS BY ADVANTAGE In Part 1 (on page 12), we explored how relationship-based incentives can go beyond one-time cash bonuses to drive lasting engagement. But incentives alone aren’t enough — true loyalty is built through personalization, purpose and connection. PERSONALIZATION BUILDS RELEVANCE — AND RETENTION Today’s consumers don’t just want a bank — they want a partner that understands their goals. A cash bonus may bring them in, but personalization is what keeps them engaged. By using data and behavioral insights, financial institutions can tailor experiences that feel relevant and proactive. Whether it’s a customized onboarding journey, budgeting tools for PART 2: Community Banker 23
Turning a new account into a long-term relationship requires more than a sign-up bonus. This six-step journey shows how everyday engagement leads to lasting loyalty. Here’s how strategic onboarding and everyday tools can turn a new account into a lasting relationship. first-time earners or targeted messages during life events like tax season or back-to-school, these personalized moments create emotional stickiness. Behavior-based rewards, goal-setting tools or even custom alerts can reinforce positive habits — and your role in supporting them. Personalization shows empathy, builds trust and transforms a transactional relationship into a lasting one. COMMUNITY CONNECTION: A BUILT-IN ADVANTAGE Local financial institutions have something national brands can’t replicate: authentic community presence. Your institution isn’t just in the neighborhood — you’re part of it. From sponsoring youth sports to volunteering with local nonprofits, your visibility in the community resonates with values-driven consumers — especially younger generations who care about where their money goes and how it’s used. These real-world touchpoints create brand loyalty that goes far beyond digital offers. When account holders see their institution actively contributing to their community, it strengthens the relationship in powerful, human ways. TRUST IS THE REAL VALUE When you combine personalized service, relevant tools and meaningful community presence, you create more than just an account — you create a trusted relationship. With trust, you can drive: • Higher retention. • Greater product adoption. • Increased lifetime value. • Stronger word-of-mouth referrals. 24 Community Banker
HOW TO BUILD LOYALTY THAT LASTS Cash offers may open the door — but they rarely build the kind of connection that drives long-term growth. By investing in personalization and community engagement, financial institutions can strengthen relationships that endure well beyond the first deposit. ADVANTAGE is a trusted consulting partner for community financial institutions across the nation. We deliver consumer-focused overdraft solutions, compliance expertise, account acquisition strategies and technology consulting to help institutions strengthen revenue, reduce risk and grow market share. Learn more at advantage-fi.com. Incentives alone aren’t enough — true loyalty is built through personalization, purpose and connection.
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