ISSUE 2 2026 Bankers & Guns Get Ready For Some Fun in Historic Butte MIB 2026 Convention & Trade Show
19 12 6 4 PRESIDENT’S MESSAGE Show Up, Learn and Grow By Loren Brown, President, MIB 6 EXECUTIVE DIRECTOR’S MESSAGE The Value in Connections By Shane Scanlon, Executive Director, MIB 8 FLOURISH Getting to the Core of Innovation By Rebeca Romero Rainey, President and CEO, ICBA 10 FROM THE TOP Ensuring the Future of Community Banking By Alice P. Frazier, Chairwoman, ICBA 12 MIB FEATURED ASSOCIATE MEMBER United Bankers’ Bank 14 2026 MIB Convention and Trade Show July 22-24, 2026 15 2026 MIB Convention Speakers 18 2026 MIB Convention Activities 19 Bank of Bozeman Awarded Best Small Community Bank to Work For! 20 MIB at ICBA LIVE March 6-9, 2026 22 Compliance Q&A By Bill Showalter, Senior Consultant, Young & Associates Inc. 24 4 Issues Driving ICBA’s Government Relations Team in 2026 Stablecoin, the GENIUS Act and CFPB Activity Are Focuses for Community Bank Advocacy This Year By Bridget McCrea, ICBA 26 2026 MIB Membership Directory 26 MIB Associate Member Banks 27 MIB Associate Member Resource Guide Contents ISSUE 2 2026 2026 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 Shawn Dutton, ICBA State Director First Security Bank of Roundup sdutton@1stsecurityroundup.com 2026 MIB BOARD OF DIRECTORS Amanda Burgess Madison Valley Bank, Ennis Tom Christnacht First Security Bank of Deer Lodge Bill Coffee Stockman Bank, Miles City Daniel Day Bank of Montana, Missoula Mike Hawthorne First Montana Bank, Missoula Logan Hensley Valley Bank of Kalispell Brice Kluth First State Bank of Shelby Kenny Martin Independence Bank, Helena 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@mibonline.org ©2026 The Montana Independent Bankers Association (MIB) | MBR Connect, formerly The newsLINK Group LLC. All rights reserved. Community Banker is published four times per year and is the official publication for this association. The information contained in this publication is intended to provide general information for review, consideration and education. The contents do not constitute legal advice and should not be relied on as such. If you need legal advice or assistance, it is strongly recommended that you contact an attorney as to your circumstances. The statements and opinions expressed in this publication are those of the individual authors and do not necessarily represent the views of 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@mibonline.org mibonline.org Community Banker 3
Show Up, Learn and Grow PRESIDENT’S MESSAGE LOREN BROWN President, MIB Hello, my friends, Every once in a while, we get the opportunity to step outside of our normal routine and be part of something that gives us a different perspective. Something that challenges us just a little, connects us with great people and reminds us why we do what we do. Those kinds of experiences do not happen by accident. They happen when we choose to show up. As I have been thinking about this upcoming year and my final convention as president of the MIB, I keep coming back to that idea. This role, this organization and the relationships I have built through it have been one of the most rewarding experiences of my professional life. It has been an adventure in the best sense of the word — one that has pushed me, taught me and connected me with an incredible group of people across our state. That is exactly what the 2026 Montana Independent Bankers Convention in Butte represents. I want to strongly encourage every one of you to attend. Whether you are a seasoned executive, a newer employee, a director or one of our valued associate members, this convention is built for you. There is something to gain for everyone, regardless of your role or how long you have been in community banking. The convention gives us the opportunity to come together as Montana community bankers and partners who all share a common purpose. It is where we learn from each other, challenge ourselves to think differently and strengthen the relationships that make our banks and our communities better. Butte is a perfect place for that. It is a city with deep roots, strong character and a history built on hard work and connection. There is a lot to experience, whether that is taking in the historic charm of the city, exploring the area or simply enjoying time with friends and colleagues in a unique setting. As always, we will have a great lineup of educational sessions and speakers covering topics that matter to all of us. These sessions are designed to provide real value that you can take back to your bank and put into practice. At the same time, the time spent outside of those sessions is just as important. The conversations over meals, between meetings and during events are often where some of the best ideas and strongest relationships are formed. There will be plenty of opportunities to enjoy your time in Butte. For those who enjoy getting out on the course, golf will be available. For those who want to explore, Butte offers a unique look into Montana’s history and character. And, of course, we will have the great meals, social events and time together that make this convention something people look forward to every year. Michelle and I are also excited to bring back the shotgun shooting event as an additional option this year. In past years, when rafting was not part of the convention, it has been a great way to give people another opportunity to get outside and try something different. For those of you who have never shot a shotgun before, do not let that stop you. We are more than happy to teach you the basics and help you feel comfortable. For those with some experience, we are glad to help you improve, and for our seasoned shooters, we will have a traditional trap competition ready to go. More than anything, it is just another way to spend time together, have some fun and build connections that carry well beyond the convention itself. This year’s convention will also mark a transition for the MIB. My term as president will come to an end, and we will welcome Amber Brown as the next president of the Montana Independent Bankers. Amber serves as president and CEO of People’s Bank of Deer Lodge, and she has been an engaged and thoughtful leader within the MIB. I have had the opportunity to work alongside her and see firsthand her commitment to community banking and to this organization. I am confident she will do a fantastic job leading the MIB over the next two years, and I look forward to supporting her as she steps into that role. Serving as president of the MIB has been an incredible experience for 4 Community Banker
from all of you, and I have a deep appreciation for the work you do every day to serve your customers and your communities. What makes this organization special is not any one person or event. It is the people who show up, participate and invest in each other. It is easy to stay focused on the day-to-day responsibilities at your own bank. We all have plenty to do. But taking the time to step away, connect with others and gain a different perspective is one of the best investments you can make. Not just for yourself, but for your team and your bank as well. As we head into this convention, I would encourage each of you to make the decision to show up. Bring a colleague. Invite someone who has never attended before. Take part in the sessions, the events and the conversations. You will get out of it what you put into it, and I can say from experience that it is well worth it. Some of the best experiences in life come from stepping into something new and trusting the process, even when you are not exactly sure what it will look like on the other side. When you do, you often come away with a better perspective, stronger relationships and a greater appreciation for the people around you. Thank you all for the opportunity to serve as your president. It has been an honor and an experience I will always treasure. I look forward to seeing many of you in Butte and continuing to be part of this great organization moving forward. Flying ahead with my fellow community bankers, Loren me. I have had the opportunity to work with so many great people across our member banks and associate members. I have learned PEOPLE. TEAMWORK. PASSION. OPPORTUNITY BANK MISSOULA BROADWAY 406.443.2340 cwg-architects.com 650 Power St. Helena, MT Strong foundations for your future. Innovating Montana financial institutions for over 65 years. Community Banker 5
The Value in Connections EXECUTIVE DIRECTOR’S MESSAGE SHANE SCANLON Executive Director, MIB ICBA LIVE! I had the opportunity to join several of our bank presidents in San Diego during the first week of March for the ICBA LIVE — and it truly was an outstanding experience. The event offered an impressive range of sessions, workshops, learning labs, a robust tradeshow and countless networking opportunities with bankers from across the country. I found particular value in sessions focused on artificial intelligence and digital strategy, stablecoins, expanding small business opportunities and evolving cybersecurity risks. The keynote speakers were equally engaging and insightful. Montana was well represented throughout the conference, and it was great to connect with our bank presidents at various events and gatherings during the week. CAPITAL SUMMIT We also attended the ICBA Capital Summit in Washington, D.C., held April 29 through May 1. Despite the last-minute schedule shuffle, we had a solid crew attending this year, and I’m very happy that everyone could accommodate the date switch. With all the critical issues currently front and center, it was a vital time for us to be on the ground. There is a great deal happening at the federal level, and it’s essential that our Congressional delegation hears directly from our bank members in-person. Currently, the House-passed housing and banking package remains at a standstill because the Senate favors — and only passed — a housing-only approach. Simultaneously, we remain closely engaged on next steps related to stablecoin policy, particularly concerning market yields, interest or rewards. H.R. 6644 — HOUSING FOR THE 21ST CENTURY ACT The House-passed Housing for the 21st Century Act includes several key provisions that strongly support community banks (source: ICBA), including: • Allowing community banks to hold additional custodial and reciprocal deposits without them being classified as brokered deposits. • Providing an 18-month exam cycle and other regulatory relief for banks with up to $6 billion in assets. • Promoting the formation of de novo community banks by streamlining the application process. 6 Community Banker
• Establishing a two-year pilot program to encourage new bank formation — especially in rural areas — by offering greater regulatory, capital and lending flexibility. • Creating a Treasury Financial Agent program to foster partnerships among minority depository institutions, rural community banks and other financial institutions. CONVENTION The Montana Independent Bankers’s 59th Annual State Convention is just around the corner, and we’re excited to host it this year in Butte at the Copper King Hotel & Convention Center. We strongly encourage every member bank to send team members to attend. There is truly something for everyone — whether you’re in executive leadership, middle management, IT or just starting your career in banking. The convention is designed to deliver both valuable educational content and meaningful relationship-building opportunities, while highlighting the critical role our community banks play across Montana. This year’s sessions will cover a wide range of timely topics, including AI in banking, innovation strategies, interest rate risk management, and both national and Montana economic outlooks. We’ll also hear directly from the banking commissioner with an important regulatory update. We’re especially excited to welcome two outstanding keynote speakers: Shon Myers, ICBA’s vice chairman and president, CEO & chairman of Farmers & Merchants Bank in Miamisburg, Ohio; and Chris Fisk, a renowned Butte historian whose passion for storytelling brings Montana’s history to life in a truly engaging way. Convention registration is available online at mibonline.org/convention. If you have any questions, please don’t hesitate to reach out to me at shane@mibonline.org. We’re looking forward to seeing everyone in Butte! www.BancardATM.com • 800-342-2731 • Columbia Falls, MT • sales@bancardatm.com ATM and ITM Sales Maintenance and Software Services Managed Services Welcome to Bancard ATM NCR ATLEOS Certified Channel Partner We bundle innovative solutions into subscriptions that run enterprises end to end. Community Banker 7
Getting to the Core of Innovation FLOURISH REBECA ROMERO RAINEY President and CEO, ICBA As community banks embrace innovation, they do so with the knowledge that each new solution becomes a product in their portfolio. With every integration comes the reliance on existing systems to support regulatory compliance, operational requirements and customer-facing usability. That generally means core integrations or top-layer API enablement to ensure functionality that delivers an optimal user experience. And quite often, that’s much easier said than done. It comes as no surprise that, by and large, community banks are dependent on their cores. As the innovation landscape evolves, so too do those relationships. Community banks remain focused on determining the right mix of integrations and layers to ensure a seamless experience for their teams and customers, while seeking to collaborate with their cores to achieve a more efficient outcome. However, while the innovation environment continues to shift, community banks’ underlying dependency on core providers remains constant. At the same time, today’s innovation landscape requires novel approaches to infrastructure that introduce new compliance requirements, and agencies are aware of this dynamic. For instance, late last year, the Office of the Comptroller of the Currency (OCC) issued a request for information on community bank engagement with core providers, seeking input on the challenges community banks face, how those concerns affect competitive positioning and ways the OCC can play a role. Community banks now must ensure that regulatory agencies and core providers both provide the elements they need to innovate. As we shared in our response to the OCC, any development that allows for innovation on a quicker, more creative basis is a win. Specifically, clearer, faster regulatory guidance that better clarifies expectations will help ease the burden on community banks. Regulatory sandboxes and pilot programs also create a way for community banks to test new solutions and offer an environment for experimentation. Core providers can also continue opening access via APIs and make those connections seamless and functional for community banks. There’s clearly a lot at play as we continue in this era of innovation, and ICBA is committed to supporting community banks with actionable guidance to help them embrace opportunities. Whether it be by researching and identifying potential partners through ICBA Preferred Service Providers, corporate members or the ThinkTECH Accelerator or by better connecting with peers via the ICBA Community to learn from their experiences, we are here to support your journey. Community banks will continue to flourish by offering the distinct solutions that they know will uniquely support their customers and communities. 8 Community Banker
| 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 – 45 years of service to community banks “As a service provider exclusively focused on community banks, Bankers’ Bank of the West is here to help strengthen our clients and the communities they serve.” Across the western states and Great Plains, we’re the place where community banks bank. That’s because we provide the services, technology, and expertise to help you extend your resources, deliver for your customers, and stand out in your market. 5 reasons to partner with us BBW - President and CEO - Bill Mitchell 1. You can unlock efficiencies and cost savings. We can provide sophisticated solutions and economies of scale because we’re powered by hundreds of community banks across our region. 5. Our priorities are aligned with yours. 2. You can expand your capabilities. 4. We’ll never compete for your customers. 3. You can count on prompt, reliable service. • Independent loan review • Loan and credit administration consultation • Strategic planning facilitation • Management, staffing, & succession planning • Acquisition & expansion • BSA/AML compliance • Regulatory risk consultation President, Jim Swanson President, Anne Benigsen • Consulting • Phishing Tests • Vulnerability Management • Security Monitoring Cyber/information security, strategic planning, independent loan review, AND MORE. Consulting Services $ 8.45B assets under management $ 1.9B daily transaction value processed/settled Serving more than 60% of community banks across 7 states
Ensuring the Future of Community Banking FROM THE TOP ALICE P. FRAZIER Chairwoman, ICBA the leap, and it was the best career decision I have ever made. However, if not for that happy turn of events, I may never have found my calling in community banking. That’s why I’m so passionate about engaging the next generation of bankers and why ICBA has made succession planning a strategic priority. It’s about opening young professionals’ eyes to the opportunities in the unique world we orbit and building the bankers of tomorrow for the long-term viability of the community banking industry. ENGAGING TOMORROW’S LEADERS We have to engage aspiring leaders in ways that speak to them, and ICBA offers avenues to do just that. For instance, if they are passionate about ensuring a fair and equitable playing field, advocacy is a perfect fit, and we want them to join us for the Capital Summit to share the community banking story with legislators. If they are focused on strengthening technology, having them attend ThinkTECH programming — whether it be the Accelerator, Innovation Workshop or Solutions Forums — will help them uncover ways community banks can apply technology to meet customer and community needs. If they want to expand their horizons and learn about new areas within the bank, they can attend courses or sign up for certification programs to uncover the specifics of unique roles within banking. Or perhaps all of these options speak to them, and the answer is to engage more deeply with ICBA and link up with other I am a community banker through and through, and very proud to be, but it was not a planned career path. In fact, I came into community banking through a fortuitous experience: I was looking to evolve my skills as an auditor while balancing career and family when a role with a community bank client of mine was presented to me. I decided to take 10 Community Banker
Recognize that every time we are able to help a customer, we’re empowering them to fulfill their dreams, a feat not many other professions can claim. QUOTE OF THE MONTH “Whatever makes you uncomfortable is your biggest opportunity for growth.” — Bryant McGill bankers in the ICBA Community, as a volunteer, at events and more. Let’s commit to this: to identify, mentor and educate the next generation. Whatever road that takes us down — advocacy and working for change, innovation and leveraging bank technologies, or education to build professional skills — our job is to ensure that the next generation of bankers recognize the value and opportunity that lies within this role. There’s no greater career than community banking, and we need to ensure we’re delivering that message, with both words and actions, to those who will be the future of our banks. Alice P. Frazier is president and CEO of Potomac Bank in Charles Town, West Virginia. Partner with us for: • Loan participation purchases and sales* • Bank stock financing • Bank executive and employee financing Member FDIC Committed to Your Growth and Success *We do not reparticipate loans. MRK-6461 Craig McCandless SVP/Correspondent Banking Business Development Officer Based out of Billings, Mont. Covers: Montana, Wyoming and Idaho 406.850.3790 Community Banker 11
United Bankers’ Bank MIB FEATURED ASSOCIATE MEMBER At United Bankers’ Bank (UBB), “First for Your Success” is more than a tagline — it’s a commitment that has guided the nation’s first bankers’ bank since 1975. While the banking landscape has shifted dramatically over the past five decades, UBB’s role has remained constant: to provide community banks with the products, services and support they need, without ever competing against them. Leading the organization are Jim Amundson, CEO, and Jen Severson, President and CFO. Jim joined UBB in July 2025, bringing more than 30 years of community banking experience, including nine years as President and CEO of BankIn Minnesota, the association serving Minnesota’s community banks — much like MIB in Montana. Jen has been with UBB for five years and has more than two decades of experience spanning community, regional and de novo banks in credit, lending, finance and operations. We sat down with Jim and Jen to discuss the role of bankers’ banks, the challenges facing community banks today, and their deep commitment to serving financial institutions across the Midwest, including Montana. Tell us a bit about who you are and what you do at UBB. Jen: I serve as President and CFO. I’ve been with UBB for five years and took on the role of President in July 2025. I oversee risk, finance, accounting and business services. Jim: I’m coming up on a year with UBB in July, after spending most of my 30-plus-year career in community banking in the Twin Cities. As CEO, I oversee the major executive functions of the bank, and Jen and I work closely together to lead the organization. You both have deep community banking backgrounds. How has that guided your work? Jen: I’ve spent my entire career in community banking — from large regional banks to de novo start-ups to family-owned banks in several states. That range of experience, 12 Community Banker
especially in credit and lending, helps me relate to what our clients are facing. Jim: Same for me. My background helps me understand firsthand what community banks need from a partner like UBB. UBB pioneered the bankers’ bank model. How has the industry changed since 1975? Jim: When UBB was founded in 1975, we were the nation’s first bankers’ bank. Our purpose was to provide correspondent banking services to community banks without competing with them — and that remains core to who we are. Since then, the number of community banks nationwide has declined, but many of the banks that remain are larger, more efficient and leveraging technology in new ways. Technology has been the biggest change overall; decades ago, we were literally shipping paper checks across the country by plane. Now everything is digital. While the tools have changed, our commitment to serving community banks — and not competing with them — hasn’t changed in 50 years. What challenges are community banks facing today? Jen: Succession is a big one. Many family-owned banks have aging shareholder bases, and the next generation doesn’t always want to stay in the smaller communities where the bank is located. Ownership transitions — including estate-driven sales — can force a sale even when the bank is still strong. And running a smaller bank is hard. You’re expected to meet the same regulatory requirements as everyone else, but with fewer resources. That’s where UBB can help. Jim: If you look only at the number of charters, it appears the industry is shrinking. But it’s more nuanced than that. Today’s community banks generally have larger asset bases, employ more people and are more efficient. Still, succession issues and regulatory burdens — especially since the post–Great Recession era — remain real challenges. How does UBB help banks manage those pressures? Jim: We’re strong advocates for community banks — serving more than 1,000 institutions. While we’re not a lobbying firm, we do work to ensure lawmakers understand the unique needs of community banks and why they must be protected. What are the biggest ways community banks rely on UBB today? Jim: Many banks depend on us for daily settlement — the essential movement of money in and out of the bank through wire transfers, electronic payments and other channels. It’s foundational work, and they trust us to get it right. Beyond that, some banks rely on our consulting teams for compliance support, loan review, HR guidance or other advisory services. Jen: Lending limits are another big one. We support participation lending and offer liquidity solutions, including Fed funds lines. Regulators want to see multiple funding sources, and we help provide that diversification. Our approach is comprehensive. UBB aims to offer a broad array of services so clients can pick what they need — whether that’s settlement, compliance support, valuations, HR consulting or loan participation opportunities. That sounds like a similar role to what community banks provide their own customers. Jim: Exactly. I spend a lot of time meeting with our clients and shareholders, including a recent visit to Montana. What I consistently hear is how much they appreciate the personal, proactive support they receive from our operations and service teams. We help resolve issues quickly and with far less friction than larger institutions can provide. Jen: Everyone at UBB is passionate about community banking. That’s why people work here — because we believe deeply in keeping community banks relevant, independent and successful. Many of us, including Jim and me, have been UBB clients ourselves in past roles. We understand the value because we’ve lived it. Any final thoughts you’d like to share with community banks in Montana and across the Midwest? Jim: Montana is a very important state for us, and we have a strong client base there. We also value the work MIB does as a state association — they’re a tremendous resource for the industry. At the end of the day, our biggest message is simple: we will never compete with you. That matters. Some competitors may offer certain services at a slightly lower price, but they may also compete with you in other areas — retail, commercial, ag lending, you name it. We believe the total relationship matters, not just the standalone transaction. Jen: And we genuinely care about our clients. We want to help them grow, remain independent and thrive in their communities. That’s the heart of what we do. Community Banker 13
2026 MIB KEYNOTE SPEAKERS Shon Myers, Vice Chairman, ICBA Shon Myers is vice chairman of the Independent Community Bankers of America (ICBA), the only national organization exclusively representing community banks. He also serves as president, CEO and chairman of Farmers & Merchants Bank in Miamisburg, Ohio. Myers serves on ICBA’s Executive Committee, Federal Delegate Board and Board of Directors and is active on several policy and operations committees. He is a past chairman of the Community Bankers Association of Ohio and remains deeply involved in his community through Rotary International, the Miamisburg Municipal Trust Fund Finance Committee and the Miamisburg Community Foundation, where he serves as vice president. He holds a bachelor’s degree in business administration from Kentucky Christian University and is a graduate of the Graduate School of Banking in Madison, Wisconsin. Convention Speakers Chris Fisk, Butte Historian Chris Fisk is one of Montana’s most respected historians and a distinguished history teacher at Butte High School. Known for his engaging storytelling style, Fisk brings Butte’s rich history to life for students, visitors and locals alike through popular trolley tours and his “Spooks and Spirits” ghost hunts in Uptown Butte. In his keynote presentation, “A Night in Butte History,” Fisk will explore the people, places and legends that shaped Butte — from mining and politics to headframes, hauntings and the Copper Kings — inviting questions and discussion along the way. SEMINAR SPEAKERS Kristina A. Morris, Vice President of Innovation Investments, ICBA Kristina Morris serves as vice president of innovation investments at ICBA, where she leads portfolio management and program development to advance the organization’s innovation strategy. Previously, she served as project manager for FinTech Atlanta and held roles with The Community Foundation for Greater Atlanta and Big Brothers Big Sisters of Metro Atlanta. Morris holds a bachelor’s degree from Emory University and an MBA from the University of Georgia. She currently serves on the Atlanta Community Food Bank Advisory Board and the University of Georgia Alumni Association’s Atlanta Chapter Board. Community Banker 15
Casey Balcerzak, Vice President, Chief Information Officer, Opportunity Bank Casey Balcerzak is vice president and chief information officer at Opportunity Bank of Montana, where he leads enterprise technology strategy and operations, focusing on resilience, security and scalable growth. With more than 20 years of IT leadership experience, Balcerzak brings expertise in enterprise systems, digital transformation, vendor management and regulatory support. He holds a bachelor’s degree in business administration with an emphasis in information technology and is a graduate of the Graduate School of Banking at Colorado. Based in Helena, he enjoys outdoor activities and community involvement. Tom Keenan, Principal, Keenan & Partners Tom Keenan is principal of Keenan & Partners, a consulting brokerage and advisory firm specializing in valuation, transactional brokerage and capital markets services for financial institutions. Founded in 2010, the firm emphasizes integrity, excellence and personalized service. Keenan has overseen more than $3 billion in valuation assignments and over $750 million in transactional volume, including more than 275 branch and facility assignments since 2014. He holds a B.A. from the College of Wooster and maintains multiple real estate broker licenses across several states, as well as FINRA Series 7 and 63 securities licenses. Keenan resides in Portland, Oregon, with his family. Dan Stimpson, Managing Director, Stifel Dan Stimpson is a managing director in Stifel’s strategy and analytics department, working with portfolio managers to optimize returns while balancing liquidity, risk and capital constraints. Before joining Stifel in 2022, he spent more than 10 years as a strategist at Vining Sparks and began his career at KPMG, followed by service as a corporate controller at a community bank. Stimpson holds undergraduate and graduate degrees in accounting from the University of Mississippi and is a certified public accountant, holding membership in the American Institute of Certified Public Accountants and the Tennessee Society of Certified Public Accountants. SEMINAR SPEAKERS 16 Community Banker
Jeffrey Michael, Director, Bureau of Business and Economic Research, University of Montana Jeffrey Michael is director of the Bureau of Business and Economic Research (BBER) at the University of Montana. His work spans regional economic forecasting, public policy analysis and environmental economics, including research on climate change, land use, infrastructure and employment growth. Prior to joining BBER, Michael held senior academic and leadership roles at the University of the Pacific and Towson University. He holds a Ph.D. in economics from North Carolina State University, a master’s degree from the University of Maine and a bachelor’s degree from Hamilton College. Mandy Fisher, Vice President, Chief Information Security Officer, Opportunity Bank Mandy Fisher serves as vice president and chief information security officer at Opportunity Bank of Montana, leading programs across information security, physical security, third-party risk management and financial crimes, including fraud and BSA/AML. With more than 14 years of experience in risk, compliance and security, Fisher develops enterprise programs aligned with NIST, FFIEC and COSO standards. She holds a master’s degree in accounting with an emphasis in forensic accounting and maintains multiple industry certifications, including CPA, CFE and CISSP. A Helena native, she enjoys traveling and outdoor adventures with her family. Melanie Hall, Commissioner, Montana Division of Banking and Financial Institutions Melanie Hall is the commissioner of the Montana Division of Banking and Financial Institutions, overseeing all state-chartered banks and credit unions, as well as more than 2,000 licensed non-bank financial entities. The division also manages consumer complaint resolution for financial services across Montana. Hall holds a bachelor’s degree in economics from Eckerd College and a J.D. from Tulane Law School. She is a past chair of the Conference of State Bank Supervisors and serves on multiple national and Montana-based education and foundation boards. Community Banker 17
2026 MIB Convention Activities ANNUAL MIB GOLF TOURNAMENT Thursday, July 23, 11 a.m. Butte Country Club 3400 Elizabeth Warren Ave. Butte, Montana With outstanding views of the nearby mountain ranges, the Butte Country Club is a scenic, historical course that offers an enjoyable challenge for any golfer. Win prizes and enjoy a day out on the links with fellow bankers and vendors! ‘BANKERS & GUNS’ TRAP SHOOTING Our Annie Oakley Shootout is $100 per person and includes gun rentals, ammo, clay pigeons and instruction. No experience necessary! Thursday, July 23, 11 a.m. Butte Trap Club 70 Basin Creek Rd. Butte, Montana Courtesy of The Annie Oakley Center at the Garst Museum
Bank of Bozeman Awarded Best Small Community Bank to Work For! the Independent Community Bankers of America (ICBA) presented Bank of Bozeman with the award for Best Small Community Bank to Work For at ICBA LIVE in March. The bank’s 24 employees were sent a questionnaire revolving around the work environment, promotions and pay, all key factors taken into consideration for the award. Bank President Clinton Gerst’s emphasis on a promotion-focused culture, plus the bankers’ positive responses to the questionnaire, truly show why the bank is the best community financial institution to work for in the country. Congratulations to Bank of Bozeman for this incredible recognition! Community Banker 19
MIB at ICBA LIVE March 6-9, 2026 MIB was well represented in San Diego during the ICBA LIVE event. Thank you to all the bankers who attended and gained educational and informative insights. We extend our gratitude to the following sponsors of the MIB reception: BHG, Bell Bank and UBB. “It is one of the most comprehensive educational opportunities available. The expo is first rate; several exhibitors told me this is their favorite event.” “ICBA LIVE is the premier event of the year, connecting community bankers from across the country. We are stronger together.” 20 Community Banker
“There is no better community bank-focused event in America than ICBA LIVE. The educational content is 100% focused on a community banker’s success.” commerce.mt.gov/housing • Down payment assistance • Low-interest 30-year mortgages • Quality loan servicing • Reverse annuity mortgages for senior homeowners The Montana Board of Housing offers: Ask a participating lender today! This message is brought to you by the Montana Department of Commerce. Community Banker 21
COMPLIANCE Q & A ECOA/TILA. Q: Due to the current cost of credit reports, bank management would like to charge the customer for a credit report at the time of application. Does the credit report fee need to be disclosed in writing before accepting a loan application for auto and unsecured loans? I am mainly concerned about disclosure requirements in the event a loan does not reach consummation, such as being denied due to credit, and the fee was paid by the consumer at the time of application. No disclosure would generally be provided in such a case. However, “before consummation” in this case is before an event that will not happen; therefore, am I correctly reading that, even though a consumer made a financial investment in the transaction, a disclosure would not be required by either Regulation B or Regulation Z because consummation did not occur as defined by state law? A: The bank is permitted to collect the credit report fee at application. The fee it charges has to be bona fide and reasonable. There is no regulatory requirement in the federal consumer rules we address that requires disclosure in a case like this. The bank may, if it desires, create a form that the borrower signs. Of course, if the loan does close, the fee must be included as part of the finance charge for non-real estate loans. The bank should ensure that all lenders charge the fee for all applicants to avoid fair lending issues. The bank also may want to double-check its state law to make sure it does not require some form of disclosure. EFTA. Q: Our Operations Department is currently reviewing a dispute in which the customer notified the bank on 3/9/26 that weekly charges of $19.99 being charged to her debit card. The charges began on 12/12/25. The first statement showing the initial charge was on 1/5/26. As it stands now, the bank will absorb all unauthorized charges. However, when our Operations Department contacted the customer for more information, she stated that she saw the charges last month but didn’t call the bank right away and then forgot about them until 3/9/26. Is the bank obligated to use 3/9/26 as the date of first contact, or can we use the customer’s knowledge of the charges a month earlier to recalculate the customer’s liability? A: Regulation E error resolution time limits are dependent on how long it is (after the first statement reflecting the BILL SHOWALTER Senior Consultant, Young & Associates Inc. error) before the customer notifies the bank of an error reflected on a periodic statement, not on how long it is after the customer first notices the error on that statement. So, in this case, the first statement reflecting the error is dated 1/5/2026. If that is also the date the statement was sent, then the customer has 60 days after that date — until Friday, March 6, 2026 — to notify the bank of the error for a timely notice. If the notice is not timely, the bank is not bound by the error resolution time limits and notice requirements of 12 CFR 1005.11. However, if the asserted error involves unauthorized EFTs, then “the institution must comply with § 1005.6 before it may impose any liability on the consumer.” Section 1005.6 requires the bank to still hold the customer harmless for any unauthorized EFTs occurring within 60 days after the first statement was sent that reflected the unauthorized EFT (or series of EFTs). However, the bank would be able to hold the customer liable for any such EFTs that occurred after 60 days, but before notifying the bank. So, in your scenario, if any occurred over that weekend between March 6 and Monday, March 9, the customer could be held liable for them. TILA. Q: Our borrower wants to pledge rental properties they already own as collateral to get one lump sum from us that they will use to construct a new primary residence. We will not have a security interest in the new residence at all. Would this loan be a “home equity loan” for TRID purposes or a “construction loan”? 22 Community Banker
A: Assuming the rentals are owned free and clear, then this would be a “home equity loan.” A “construction loan” must be for the purpose of the initial construction of a dwelling and be secured by that dwelling. Since the bank will not hold a mortgage in the new residence, this would be a “home equity loan” (since it also is not a “purchase” or a “refinance”). RESPA. Q: We have a loan that is delinquent and has a surplus in its related escrow account. This account just went through the annual escrow account analysis and has a sizable surplus. Can the bank apply the surplus to the delinquent loan? A: No, the bank may not. If the borrower is current, the surplus (> $50) must be refunded to the borrower. If the borrower is not current at the time the surplus is determined, the surplus may be retained in the escrow account. No provision is made to allow the lender to take the surplus to satisfy delinquent amounts, late fees or similar loan charges. CRA/HMDA. Q: We are an HMDA reporter and eligible for the partial exemption. I am thinking of switching our loan software to support the exempt fields. What considerations do I need to be aware of for CRA reporting if I make these changes? Currently, we are a small intermediate reporter for CRA. A: There is probably no real CRA impact in taking advantage of the partial exemption. Looking over the exempt data points, there do not seem to be any that would affect the bank’s chances of a CRA “satisfactory.” Flood Insurance. Q: We have a property securing a loan that was not in a flood zone when the loan was originated, but the map has since changed, and the property is now in a flood zone. Since this happened after the loan was originated, does the bank have to escrow for flood insurance? A: This is not one of the “triggering events” — making, increasing, renewing or extending (MIRE) — a loan, so starting escrow of flood premiums is not mandated. However, remapping is one of those situations in which the lender may have the right (depending on their loan documents) but not the obligation (by regulation) to escrow flood insurance premiums. It becomes a bank decision about whether to protect its security property. SAFE Act. Q: Are bank employees who are “mortgage loan originators” (MLOs) with NMLS numbers required to take continuing education training each year, as required for state-licensed MLOs? A: No, MLOs who are registered on the federal registry because they serve as MLOs for federally insured financial institutions are not subject to any continuing education requirements to maintain their NMLS numbers and registration status. SCRA. Q: We have an applicant for a vehicle loan who is a member of the military and is on active-duty status. Are we allowed to charge our going vehicle loan rate, even if it is in excess of six percent (6%)? A: Yes, since your borrower is already on active-duty status, they are not covered by the Servicemembers Civil Relief Act (SCRA) interest rate limit. That is a protection that applies only to pre-active-duty debt. 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. Community Banker 23
4 Issues Driving ICBA’s Government Relations Team in 2026 Stablecoin, the GENIUS Act and CFPB Activity Are Focuses for Community Bank Advocacy This Year By BRIDGET McCREA, ICBA community banks entered 2026 with numerous legislative and regulatory issues in play. While some are familiar pressure points, others reflect how newer policies and technologies are increasingly appearing in real proposals and oversight. Here are four issues ICBA’s government relations team is closely engaged with as the year unfolds. 1. REGULATORY RELIEF PUSH Regulatory relief for community banks has been a central legislative priority throughout the 119th Congress. Early in the session, the House Financial Services Committee introduced a new agenda that targets compliance pressure through a package of relief measures designed for smaller institutions. “At the beginning of this Congress, the chairman of the House Financial Services Committee launched an agenda called Make Community Banks Great Again,” says Paul Merski, EVP of congressional relations at ICBA. “With that, we’re pushing a number of legislative packages and bills to reduce the regulatory burden on community banks.” Progress on this initiative has included House passage of several regulatory relief provisions in the ICBA-advocated community banking title of the Housing for the 21st Century Act (H.R. 6644) as well as the introduction of the comprehensive Main Street Capital Access Act (H.R. 6955) by House Financial Services Committee Chairman French Hill and committee member Andy Barr. “Reducing the regulatory burden is one of our top priorities,” Merski says. “Passing that legislation through the House and Senate during this Congress would make a real difference.” Community bankers can support these efforts by engaging directly with lawmakers through ICBA’s Be Heard grassroots action center and by attending the annual ICBA Capital Summit. “When community bankers weigh in directly with members of Congress, it matters,” Merski says. “That engagement helps us speak with a broader, louder voice.” 2. STABLECOIN AND OTHER DIGITAL ASSETS The current Congress is closely focused on legislation to reform the digital asset market structure, intended to establish a regulatory framework for crypto assets and intermediaries. ICBA has been closely engaged with policymakers on stablecoin policies. “The digital asset space is very broad, but the current focus is on stablecoin,” Merski says. “We’re watching how banks and nonbanks could issue stablecoin and how new legislation and regulation could affect community banks.” Community banks are paying close attention to proposals that could allow stablecoins to pay interest or yield, which Merski says could disrupt traditional deposit relationships. “We’re particularly focused on making sure stablecoin doesn’t pay interest or yield,” he says. “That could displace community bank deposits if it moves forward.” ICBA is actively engaged on the legislative front and encourages members to stay informed and involved. “This is an area where bankers really need to get up to speed and weigh in,” Merski says. “We’ve identified specific concerns and provided tools through our grassroots action center, where bankers can engage on both the policy and business implications.” 3. IMPLEMENTING THE GENIUS ACT Meanwhile, federal regulators have begun rulemaking on previous stablecoin legislation, putting the GENIUS Act into focus for community banks in 2026. After Congress passed the law last year, agencies are now drafting 24 Community Banker
proposals to determine how its provisions will apply in practice. “We’re starting to see regulatory proposals implementing the GENIUS Act, and we expect that to continue throughout the year,” says Lilly Thomas, EVP, regulatory relations and strategy at ICBA. For community banks, the details of those rules will shape compliance expectations and competitive balance. Thomas says outcomes will depend on how regulators translate statutory language into supervision and oversight. “The devil’s in the details when it comes to the regulations,” she says. “We want to make sure there’s a level playing field for community banks.” ICBA is tracking agency rulemaking tied to the GENIUS Act and engaging as proposals emerge. Thomas says community bankers should stay engaged as regulators request feedback and refine their approach. “This is going to be top of mind as rules take shape,” she says. “How regulators implement the law will matter just as much as the legislation itself.” 4. CFPB ACTIVITY INTENSIFIES Consumer Financial Protection Bureau (CFPB) activity is shaping up as another major focus area for community banks in 2026. Questions around the bureau’s funding remain unresolved, while several high-impact rulemakings continue to move forward. Two of the most closely watched issues include Section 1071, Small business data collection and Section 1033, Consumer rights to access information. Regulators are expected to release further action on both, which could affect compliance obligations for community banks. ICBA is working to ease regulatory burden as rulemaking advances amid competing pressures from consumer groups and fintech firms. As agencies develop proposals and seek public input, Thomas emphasizes the importance of member participation. “As we draft comment letters and responses, we depend on community bankers to weigh in through our grassroots action center,” she says. “Watching for action alerts and responding is very important, and how we make sure the community bank voice continues to be heard.” Bridget McCrea is a writer in Florida. MAKE YOUR VOICE HEARD Visit icba.org/advocacy for information and tools that will help you lobby your legislators on community banking issues. Sometimes SBA lending decisions are difficult. But not this one. q ICBA’s only Preferred Service Provider for SBA and USDA lending Get started today. 800.340.7304 holtandmon.com ICBA’s only choice makes yours easy. Our industry experts handle the hard work at no net cost to your bank, while you empower small businesses and earn non-interest fee income. Over 40 years of serving community banks add up to trusted data, processes and procedures that meet stringent SOC 2, Type II security and privacy standards set by the American Institute of Certified Public Accountants. No other company comes close. TM Community Banker 25
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