ISSUE 3 2026 2026 MIB Convention & Trade Show Highlights
24 12 4 4 PRESIDENT’S MESSAGE Work Worth Doing By Amber Brown, President, MIB 6 EXECUTIVE DIRECTOR’S MESSAGE Butte Raises the Bar By Shane Scanlon, Executive Director, MIB 8 2026 MIB Convention & Trade Show Highlights July 22-24, Butte, Montana 10 Thank You Convention Sponsors! 12 Showing Up for People A Q&A with 2026 MIB Young Banker Award Recipient Caden Harkins 15 SAVE THE DATE Women in Banking Conference 16 Compliance Q&A By William J. Showalter, CRCM, CRP, Senior Consultant, Young & Associates Inc. 18 Proactive Planning for CRA Success By William J. Showalter, CRCM, CRP, Senior Consultant, Young & Associates Inc. 20 WOMEN IN BANKING CONFERENCE Crafts & Connections 20 Join Us at the MIB Griz Tailgate! 22 6 Community Banking Wins in the First 6 Months of 2026 By Rebeca Romero Rainey, President and CEO, ICBA 24 The Threshold of Life Memorial How You Can Support Montana’s Organ and Tissue Donors 26 2026 MIB Membership Directory 26 MIB Associate Member Banks 27 MIB Associate Member Resource Guide Contents ISSUE 3 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 shane@mibonline.org Holly O’Malley, Executive Assistant holly@mibonline.org ©2026 The Montana Independent Bankers Association (MIB) |MBR Connect™. 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 (801) 676-9722. MONTANA INDEPENDENT BANKERS 1812 11th Ave. PO Box 4893 Helena, MT 59604 (406) 449-7444 shane@mibonline.org mibonline.org Community Banker 3
Work Worth Doing PRESIDENT’S MESSAGE AMBER BROWN President, MIB It is a tremendous honor to serve as president of the Montana Independent Bankers Association. I am grateful for the confidence placed in me by our Board of Directors and member banks, and I look forward to working alongside each of you as we continue MIB’s proud tradition of advocating for Montana’s independent community banks. My community banking journey began in August 2000, with Peoples Bank of Deer Lodge, where I started as a teller. From my first day as a teller to my current role as president and CEO, Peoples Bank of Deer Lodge has been the constant throughout my banking career. I am grateful for the opportunities, relationships and experiences that have allowed me to grow alongside an institution that remains deeply committed to its customers and community. As I reflect on my career, I am especially grateful for the mentors and leaders who invested in me along the way. Their guidance and encouragement helped shape both my professional growth and leadership philosophy. I would also like to extend my sincere appreciation to Loren Brown for his leadership and service as MIB president over the past two years. Loren led this association with vision, integrity and a steadfast commitment to Montana’s independent community banks. Community banking has always been built on relationships, mentorship and a shared commitment to serving others. The mission of the Montana Independent Bankers Association remains as important today as it was when the organization was founded over 55 years ago: promoting competition among financial institutions so that premier financial services remain available to the customers and communities we serve. Just a few weeks ago, I had the opportunity to visit the newly opened Theodore Roosevelt Presidential Library in Medora, North Dakota. As I walked through the exhibits, I reflected on Roosevelt’s legacy of service, leadership and action. More than a century later, his commitment 4 Community Banker
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. to public service continues to influence our nation and future generations. What struck me most was the reminder that lasting impact comes from stepping forward and taking action. That lesson is especially relevant for all of us in community banking. Every day, we have opportunities to make a meaningful difference, whether by helping a customer achieve a dream, supporting a local business, mentoring a colleague or strengthening the communities we call home. I am reminded of a Theodore Roosevelt quote that speaks to the value of effort: “Far and away the best prize that life has to offer is the chance to work hard at work worth doing.” Roosevelt understood that strong communities are built by individuals willing to engage, serve and contribute. The same is true of our association. Our success is built on the collective commitment of independent bankers across Montana. As president, I encourage every member to become actively engaged in MIB. Attend an event. Participate in our advocacy efforts. Invest time in developing the next generation of community banking leaders. Share your expertise and experiences with your fellow members. Every voice matters, and every level of involvement strengthens our association and our industry. As we look to the future, I invite each of you to consider how you can help shape the next chapter of independent banking in Montana. Community banking has thrived because bankers have always stepped forward to serve. Together, we can ensure that our voice remains strong, our communities remain vibrant, and our industry continues to prosper for generations to come. Thank you for the opportunity to serve as your president. I am confident that, working together, we will continue to strengthen Montana’s independent community banks and the communities that depend on them. Let’s lead with purpose, serve with commitment and take action for the future of community banking in Montana. Community Banker 5
EXECUTIVE DIRECTOR’S MESSAGE Butte Raises the Bar SHANE SCANLON Executive Director, MIB wow — what a convention! More than 150 community bankers, associate members, speakers, sponsors and friends joined us in Butte, making the 2026 gathering the largest convention we have ever held in the Mining City. While turnout was remarkable, it was the energy in every education session, reception and outdoor activity that truly made the week memorable. An event of this size and quality is a team effort, and our thank-you list is long. Our Premier Level Sponsors stepped up in a meaningful way, and our Event Sponsors helped make each block of the event possible. Our exhibitors, speakers, volunteers, board members, bank and associate members, and attendees each made this such a special event, and we are grateful for everyone’s support and enthusiasm for our 59th Annual Convention. A WARM WELCOME — AND PERFECT TIMING The Wednesday evening Welcome Reception set the tone with a phenomenal turnout. As storm clouds gathered over Butte, bringing some relief from the summer heat, we enjoyed the evening and wrapped up just ahead of the downpour that soon arrived in full force. It felt like a small convention miracle, and a fitting start to a week when so many things came together just right. Thursday morning began with breakfast and our Member Meeting. It was encouraging to see so many members engaged as we shared an update on the association’s work and the developments shaping the year. From ICBA LIVE in San Diego and our advocacy efforts in Washington, D.C., to meetings at the Federal Reserve Bank of Minneapolis’ Helena Branch, interim legislative work ahead of the 2027 session and legislative updates from the Blockchain Task Force, there was plenty to discuss. As we moved into our seminars, Kristina Morris, vice president of innovation investments at ICBA, opened the educational program with “Community Banking Innovation: What Innovation Looks Like Now.” Her presentation offered an impressive and practical look at how innovation is evolving for community banks and what leaders should be thinking about now. Dan Stimpson, CPA, managing director at Stifel Solutions, followed with “Optimizing Banks’ Interest Rate Risk Management.” His timely update gave attendees a useful perspective on how to navigate interest rate risk in a complex operating environment. FRESH AIR, FRIENDLY COMPETITION AND A MEMORABLE EVENING Thursday afternoon’s outdoor activities went off without a hitch, giving attendees an opportunity to spend time together outside the meeting room. We cannot thank Joel Rosenberg and Loren Brown enough for leading the golf outing and trap shoot. Their planning and steady leadership helped make both activities enjoyable from start to finish. The Vendor Reception held that evening offered time to visit exhibitor booths, catch up and continue conversations from earlier in the day. We also kicked off the PAC Auction, and Mike Hawthorne knocked it out of the park in leading this effort. As I said that night, we really need Mike to keep this tradition going next year! We were thrilled to welcome Shon Myers, vice chairman of ICBA and president, CEO and chairman of Farmers & Merchants Bank in Miamisburg, Ohio, to Montana. We were among Shon’s first stops on the convention circuit this year, and he did a terrific job. His experience as a current bank president and former chair of the Community Bankers Association of Ohio gave him an authentic and valuable perspective on the opportunities and pressures community banks face. Chris Fisk, the ultimate Butte historian and a distinguished history teacher at Butte High School, brought the evening to a close. Simply put, you cannot go wrong inviting Chris to tell the history of Butte. His presentation, “A Night in Butte History,” delivered in every way. I cannot remember hearing a room laugh so hard. Chris gave us an unforgettable mix of local history, personality and humor. A STRONG FRIDAY PROGRAM The convention continued Friday morning with a wide-ranging seminar lineup covering the strategic, 6 Community Banker
technological, economic and regulatory issues shaping community banking: • Remaining Independent: Strategies and Practices for Remaining Independent in the Age of Industry Consolidation — Tom Keenan, President, Keenan & Partners • Understanding Artificial Intelligence and Third-Party Risk — Mandy Fisher, CPA, CFE, CISSP, Vice President and Chief Information Security Officer; and Casey Balcerzak, Vice President and Chief Information Officer, Opportunity Bank • Montana Economy at Mid-Year 2026 — Jeffrey A. Michael, Director, Bureau of Business and Economic Research, University of Montana • Update from the Banking Commissioner — Melanie Hall, Commissioner, Division of Banking and Financial Institutions, State of Montana Together, these sessions gave attendees practical ideas they could take home to their institutions, as well as a clearer view of the forces likely to shape the remainder of 2026 and beyond. CELEBRATING LEADERSHIP AND SERVICE Now, I need to circle back to Thursday evening and our awards presentation; it rightfully deserves its own section. We had the privilege of recognizing some amazing individuals and organizations whose leadership, partnership and service represent the best of community banking. MVP Bank Member Award: Opportunity Bank of Montana We were proud to present the 2026 MVP Bank Member Award to Opportunity Bank of Montana. President and CEO Laura Clark is an impressive leader who has built an incredible team. Laura was one of the first board members I met when I joined the association, and I have appreciated her steady guidance and leadership. We also cannot thank her enough for spearheading the Fundamentals of Banking Course, which has seen phenomenal growth over the past year. Outstanding Associate Member Award: Bell Bank The Outstanding Associate Member Award is always one of our most difficult selections because we are fortunate to work with so many fantastic associate members. This year, we were pleased to recognize Bell Bank and its very own Craig McCandless. Although I have not known Craig long, I enjoyed catching up with him over coffee in Helena, and he has always made an effort to reach out and stay connected. He has been a true partner to MIB, consistently stepping up to support us and help our association thrive. We are grateful to Bell Bank’s dedication to MIB and proud to recognize their contributions. Young Banker Award: Caden Harkins, Three Rivers Bank of Montana Caden Harkins has distinguished himself through remarkable professional growth, advancing from personal banker to commercial credit analyst and now loan officer at Three Rivers Bank of Montana in just four years. His integrity, work ethic and commitment to serving people of all ages in his community make him an outstanding representative of the future of community banking in Montana. We were delighted to honor Caden with the 2026 Young Banker Award. THANK YOU FOR MAKING BUTTE SPECIAL To every sponsor, exhibitor, speaker, volunteer, board member, associate member, banker and guest who helped make the 2026 Convention possible: thank you. Butte gave us a record-setting turnout and an unforgettable experience. More importantly, everyone who attended helped reaffirm the strength, resilience and shared purpose of Montana’s community banks. We cannot wait to build on that momentum together through the remainder of the year and into 2027! Community Banker 7
2026 MIB Convention & Trade Show Highlights July 22-24, Butte, Montana montana’s independent bankers gathered in Butte on July 22-24 for a convention that combined timely educational sessions, networking and recreational opportunities. Attendees gained valuable insights on topics ranging from banking innovation and interest rate risk management to artificial intelligence and the state’s economic outlook. Bankers also enjoyed opportunities to unwind and connect with colleagues, including the annual golf tournament, trap shoot and Vendors’ Night cocktail reception. The President’s Banquet featured remarks from ICBA Vice Chairman Shon Myers and a fascinating evening of Butte history with local historian Chris Fisk. MIB extends its sincere thanks to every member, speaker, organizer and sponsor who helped make this year’s convention a success, as well as everyone who took the time to attend and celebrate Montana independent banking. (L-R) Opportunity Bank’s Casey Balcerzak, Mandy Fisher, Laura Clark (President and CEO), Chantelle Nash, Rachel Amdahl and Darryl Rensmon 2026 Outstanding Young Banker Caden Harkins (right) with Scott Hoerth, Three Rivers Bank of Montana 8 Community Banker
Historian Chris Fisk offers an entertaining and informative look into Butte’s past. 2026-2027 MIB President Amber Brown with husband Beau ICBA Vice Chairman Shon Myers discusses opportunities and pressures facing community banks. MIB Board Member Shawn Dutton embraces former MIB Assistant Terri James as she is recognized for years of dedicated service to the association. (L-R) MIB Board Member Kenny Martin, Terri James and Bell Bank Senior Vice President Craig McCandless Community Banker 9
Thank You Convention Sponsors! PREMIER LEVEL SPONSORS DIAMOND PLATINUM GOLD SILVER BRONZE EVENT SPONSORS Welcome Reception Bell Bank Keenan & Partners Select Bankcard Thursday Breakfast Bankers’ Bank of the West Bell Bank Holtmeyer & Monson Keenan & Partners Thursday Lunch Blackfoot Communications Vendor Reception Ascensus Blackfoot Communications FirstCall Grizzly Security Armored Express ICBA Securities, powered by The Baker Group Navanta Hosted Bar PCBB President’s Banquet ICBA Securities, powered by The Baker Group Friday Breakfast Bell Bank Keenan & Partners Golf Drinks Cart Bell Bank Select Bankcard Golf Prize Grizzly Security Armored Express Holtmeyer & Monson Select Bankcard Trap Shooting Drinks Cooler Ascensus Bell Bank Keenan & Partners Select Bankcard Stifel Trap Shooting Prize Ascensus 10 Community Banker
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Showing Up for People A Q&A with 2026 MIB Young Banker Award Recipient Caden Harkins Caden Harkins did not set out to become a banker. After graduating from college in May 2022, he simply knew he wanted to return home to Montana’s Flathead Valley. An internship at Three Rivers Bank of Montana gave him that opportunity — and introduced him to a profession built around the values he already held: curiosity, care and commitment to community. Now the MIB’s 2026 Young Banker Award recipient, he sees the honor as both an affirmation and a starting point. Caden recently sat down to discuss the mentors who shaped him, the importance of local decision-making, his full-circle service with the Highlander Track program and why the next generation of bankers should keep looking for work worth doing. What was your initial reaction when you learned you had received the award? I was super excited when I got the email from Shane congratulating me, and I was also pretty surprised. I didn’t know who else was in the pool or what to expect. It was a really happy moment. What does this recognition mean to you personally and professionally? Personally, it is rewarding to be recognized for the hard work I’ve been doing. Professionally, I see it as a launch pad. It reassures me that I’m taking the right path and doing the right things, while also encouraging me to keep going and improving from here. How did you find your way into community banking? Honestly, I fell into it. Right out of college, I didn’t know what I wanted to do; my main goal was to move home to the Flathead Valley. I saw that Three Rivers Bank had an internship and thought I would work there while I figured things out. Then I learned how involved the bank was in the community. That really interested me, so I stayed. How has your role evolved since you joined Three Rivers Bank? I started in the accounting department as an intern in May 2022. After a month or two, a personal banking position opened, and I moved into that role for just under two years. Then I became a credit analyst, underwriting commercial loans for about two years. Most recently, I transitioned into a loan officer role. I’ve been fortunate that Three Rivers Bank has given me opportunities to learn many sides of the banking industry. Who have been your most influential mentors? There are many people I could name. Joel Rosenberg, our senior vice president of commercial loans, took me under his wing and taught me how to work with customers 12 Community Banker
and see the bigger picture. Scott Hoerth, our chief lending officer and my supervisor, has helped me grow in underwriting, standards and compliance. Sherry Bailey, our office coordinator, showed me how much a positive attitude and genuine personal connections matter. Customers know her by name, and she knows their families, their work and what is happening in their lives. How do you build trust with customers and maintain strong relationships? Preparation and timeliness. You’re dealing with people’s finances, and that can be stressful. Showing up prepared, knowing what you’re talking about and responding efficiently can prevent frustration for both the customer and the banker. I’ve also learned that if you don’t know an answer, say you’ll look into it and follow up. Don’t guess; guessing only pushes you into a corner. How do community banks strengthen Montana communities? Community banks keep decisions local. Three Rivers Bank serves the Flathead Valley through three branches — two in Kalispell and one in Whitefish — so we’re closely connected to the people who live here. A community bank doesn’t serve the community from a distance; it is part of the community. What aspect of community banking are you most passionate about? The community involvement. Three Rivers Bank supports local school programs, including the Highlander Track program, a free, nonprofit initiative that gives younger kids the opportunity to participate in track. I serve as treasurer on its board. That work is especially meaningful because I ran in the Highlander as a child. About 20 years later, I’m helping keep the program going so another generation can have the same amazing experience. It’s a full circle. What motivates you to invest your time beyond the bank? It comes from wanting to help other people. I’ve always considered myself a caring person, and banking — especially lending — lets me put that instinct to use. Whether someone is building a business, supporting a family or pursuing another goal, I can help them identify what they need and work toward success. How has community involvement made you a better banker? It has shown me that knowing people personally makes conversations easier and more meaningful. Once you understand what someone cares about, you begin to understand what motivates them. That helps you see what they are trying to accomplish and how, as a banker, you may be able to help. What are you most proud of so far in your career? Along with the Highlander program, I’m proud of the attitude I bring to work. If I’m having a bad morning, I try to leave it at the door. I want to be someone who coworkers can smile and laugh with, feel comfortable around and come to with questions. Skills and knowledge matter, but the way you show up affects everyone around you. What goals are you pursuing in the next phase of your career? Long-term, I would like to move into a management or leadership position within the bank, although I don’t have a set timeline. In the short term, my focus is on becoming a better loan officer: building my knowledge, growing as a banker and becoming a more reliable resource when people come to me. What opportunities do you see for the next generation of community bankers? New technology creates a unique opportunity. Customers will still want the personal touch of a banker, but they will Community Banker 13
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 also expect speed and efficiency. Younger professionals grew up with technology, so they are well-positioned to bring those strengths together — using better tools while preserving the relationships that make community banking different. What advice would you give young professionals considering banking? Stay curious. Banking is a profession in which becoming truly good takes time — often decades. If you feel behind at first, that’s all right; everyone feels behind when they start. I certainly did. Keep learning and looking for work. I like a line from former Montana Tech football coach Bob Green: “You’ve got to be a woodpecker in a petrified forest — just keep busy and look for work.” What final message would you like to leave readers about community banking and service? Community banking and community service matter because both are rooted in showing up for people. A strong community bank is more than a place to deposit money or get a loan; it is a partner in helping families, businesses, schools and local organizations succeed. When bankers invest their time, build relationships and serve beyond the bank’s walls, they help create stronger, more connected communities. Community banking works best when it is truly about the community. 14 Community Banker
WILLIAM J. SHOWALTER, CRCM, CRP Senior Consultant, Young & Associates Inc. BSA. Q: Our customer brought in a $25,000 check from their deceased mother (non-customer) along with legal documents showing they could cash the check. The customer just wanted to deposit the funds. Our teller cashed the transit check and then deposited the funds into the customer’s account. Our system shows “cash in” and is triggering a CTR alert. Would a CTR be necessary in this instance? No cash crossed the teller line (but I’d like to think of it as imaginary cash). Reading the manual, the line “of more than $10,000 by, through, or to the bank” is throwing me off. A: No, a CTR would not be required since there was no actual exchange of currency. The bank should note the file with language similar to, “Transaction involved the deposit of a $25,000 check. The core system generated cash debit/credit entries for processing purposes only. No currency was received or disbursed; therefore, the transaction is not reportable on a CTR.” Be sure to retain appropriate documentation in your BSA files. The phrase in the BSA regulations “by, through, or to the bank” refers to actual currency movements; it does not convert a non-cash instrument into currency. The bank could look into a more accurate way to process the transaction. CRA. Q: With the repeal of the CRA regulation, I know that the bank is now examined under the old CRA rule. However, I went to the FDIC regulation in 12 CFR 345.43(c), which states that the CRA public file must be posted on the bank’s website. Can you please tell me whether this requirement has been repealed or remains in effect? A: The agencies proposed a rule to rescind the 2023 CRA rule and go back to the 1995 rule generally. We have not yet seen that proposal finalized, but they have held that, with the court action against the 2023 rule, they are enforcing the 1995 rule. The 1995 rule does not require posting anything to the bank’s website, though it also does not prohibit doing so. When the FDIC (and other agencies) adopted the 2023 rule, it was posted to eCFR on its effective date. Then the lawsuit(s) came, and the agencies put the new rule on COMPLIANCE Q & A hold. They seem to be taking their time in finalizing the proposal to roll back to the 1995 rule. TILA. Q: We have a loan customer who received the Loan Estimate, Closing Disclosure, and Notice of Right to Rescind. He signed an intent to proceed and agreed with the amounts on the CD. The funds were to be distributed on Thursday to consolidate loans. The customer is now stating that he miscalculated what he needed and actually needs additional funds. We have talked to the title insurance company, and they can update the policy easily and give us the updated premium today. Our question is: Can we just restart the timeline on this same loan by redisclosing the LE and CD and giving him the rescission notice? Or should it be considered that he exercised his right to rescind, and it must be a brand-new loan and application? A: There is no reason to restart the whole process. Document the reason for the change (customer request) in the file, then give the customer a revised CD (no need for another LE) and rescission notices. That should take care of it. ECOA. Q: On the Uniform Residential Loan Application, in the Type of Credit section, where it says “each borrower intends to apply for joint credit” and has a place to initial, do both applicants have to initial there? 16 Community Banker
Or does each applicant just initial that section in their own application? A: Having each applicant initial the appropriate place on their own application is fine. To satisfy Regulation B, each applicant must sign or initial somewhere to indicate they intend to apply jointly with the other applicant(s), not necessarily in every such space on all applications for a particular loan. EFAA. Q: Per Regulation CC, we find that our deposit-taking ATM must disclose specifically the availability periods for all types of deposit accounts. Our question is: Is the funds availability notice that is required in our lobby, where deposits are accepted, the same notice required on the ATM? Also, how many signs for the cut-off time does a bank need? Are they needed at every teller window? A: The bank does not have to post a full funds availability schedule at each ATM. ATMs require a notice at each location that funds deposited in the ATM may not be available for immediate withdrawal. This is a pretty simple notice that may either be posted on a sign on the ATM (though these tend to get picked at/removed over time) or on the screen before a consumer makes a deposit. As for notices of cut-off times, that would be part of the posted availability schedule. The bank has some flexibility in meeting this requirement. The notice must be posted in a conspicuous place in each location where its employees receive deposits to consumer accounts. The required notice must specifically state the availability periods for the various deposits that may be made to consumer accounts. The notice need not be posted at each teller window, but the notice must be posted in a place where consumers seeking to make deposits are likely to see it before making their deposits (e.g., at the point where the line forms for teller service in the lobby). EFTA. Q: To what extent is a bank responsible for fraud on debit cards? When a card is compromised, and the customer had no involvement in the transaction, we reimburse. However, what if the customer was responsible for the transaction, but unknowingly used a fraudulent website? Is the bank responsible for reimbursing them? In our case, the customer “purchased” a cruise through a fraudulent website. Is this considered coercion by the fraudster and thus covered by Regulation E? A: No, not receiving whatever they “purchased” is not an “error” under Regulation E error resolution requirements (though it is for credit cards under Regulation Z). The transaction was “authorized,” so the bank has no reimbursement obligation. FDIC Advertising. Q: In regard to the recent FDIC Official Signs and Advertisement Rule update, are all institutions now required to have written policies and procedures in place to be in compliance? A: Yes, the bank is required to have a policy dealing with the advertisement of FDIC membership requirements. The relevant subsection in the revised rule is 12 CFR 328.8(a) (Policies and procedures). Privacy. Q: I wanted to confirm our understanding of the annual privacy notice requirements under Regulation P. Last year, the bank updated its privacy policy and mailed the revised notice to applicable customers. Since that time, there have been no additional changes to the policy or our information-sharing practices. Based on our review, we believe we continue to meet the criteria for the annual privacy notice exception and, therefore, are not required to send a new notice at this time. Correct? A: Yes. If the bank shares customer information only under the exceptions in sections 1016.13, 1016.14, and/or 1016.15 and has not changed its privacy policy since last year’s mailing, it still falls within the exception. As you did last year, if another change is made, another set of notices will have to be sent out at that time — and then back to the exception (as long as the exception’s criteria are still met). Young & Associates provides banks and thrifts with support for their compliance programs, independent reviews and inbank training, as well as a full menu of management consulting, loan review, IT consulting and policy systems. Community Banker 17
Proactive Planning for CRA Success By WILLIAM J. SHOWALTER, CRCM, CRP, Senior Consultant, Young & Associates Inc. there was a lot of talk a few years ago about the regulatory agencies updating their rules implementing the Community Reinvestment Act (CRA). The Office of the Comptroller of the Currency (OCC) even revised its CRA rule. But the other agencies did not follow suit, and the OCC rescinded its amendments, reverting to the previous regulation. The last time the agencies overhauled their CRA rules was during the Clinton administration in the 1990s. So, it’s probably due — banking and the communities it serves have changed significantly in the past 20 or so years — but that effort will take some time. For now, we have to make sure we are serving our communities to the best of our abilities and complying with the current CRA rules. The 1990s-era CRA rules are more performance-focused than the previous rules, but they are not objective. The rules and examination procedures do spell out what examiners will review. However, because many subjective terms and flexible standards are used, how examiners will review CRA performance is not specified. Examiner judgment is the guiding principle here. This leaves banks not knowing whether their performance is satisfactory until after an examination is completed. Banks cannot eliminate this risk of examiner criticism entirely, but steps can be taken to significantly reduce it, including good strategic planning. WHY MANAGE CRA? Many banks feel they are doing a pretty good job of meeting the credit (and other banking) needs of their local communities. So, why should they invest significant time and effort in managing their CRA climate and performance? The answer is that good CRA performance is just good business. As with any other business function, smooth operation depends on good management. Directing the CRA function also allows banks to navigate the CRA examination process more easily and can prevent unexpected and unnecessary delays in future mergers, branching and other corporate applications. SETTING THE STAGE A bank can, to some extent, set the framework within which its performance will be judged. A formal way to do this is to choose the formal CRA strategic plan option, where the bank writes its own lending, investment and service goals with input from its community. The bank’s supervisory agency reviews and approves the plan, then assesses the bank’s performance against the plan’s goals. There is a less formal way to accomplish the same ends. A bank can formulate an internal CRA strategic plan that sets out objective standards against which its performance can be gauged. An important element of such a plan is to establish realistic goals based on local community factors (economic conditions, credit needs and demand, etc.) and the bank’s situation (size, financial condition, stability, etc.). One crucial component of such a scheme is the ongoing internal monitoring and reporting of results. An informal plan should be shared with examiners, assuming the goals are being met, to provide them with the objective standards the bank wants to use to measure its CRA performance. This allows the bank to control its destiny to a greater extent by building the gauge for rating its performance, one that accounts for its own and its community’s unique situation. Other advantages of an informal plan over a formal one are that it does not have to be negotiated with members of the public, formally approved by regulators or made public. 18 Community Banker
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. DRAFTING A PLAN A CRA plan should be developed to align with the bank’s existing planning structure and culture. It should build on the bank’s identified strengths in its performance and aim to shore up any weak areas. The team assembled to draft the plan should be diverse and represent all areas of the bank that affect and touch on CRA performance. This brings the strengths and viewpoints of a variety of bank players into the process and helps get wide “buy-in” to the plan, an important element for its success. The plan also must be tailored to fit the CRA environment within which the bank operates — the size and CRA type of the bank (small, intermediate small, large retail, limited purpose or wholesale), past CRA performance of the bank, characteristics of the bank (culture, business lines, etc.) and local community conditions (employment and income levels, economic needs, etc.). This process will guide the bank in deciding how to address its CRA responsibilities. Elements of the CRA planning and management process include: • Setting clear, attainable goals for a “satisfactory” CRA rating, and more ambitious stretch goals for an “outstanding” rating. • Managing the information about the bank’s CRA performance (data revolving around the three key tests in the CRA examination scheme for large retail banks and thrifts: lending, investments and services), including analysis of that data to get a picture of the bank’s ongoing performance. • Establishing and nurturing relationships with active community partners, with a positive approach to working together for the betterment of the local community. CONCLUSION Banks can control their CRA destiny. However, to do so, the entire process must be managed proactively — plans drawn up, goals set, information managed and community partnerships nurtured. Dynamic, ongoing management of the entire CRA process, with appropriate accountability standards for all players, can yield positive results not only for banks but also for their communities. William J. Showalter, CRCM, CRP, is a senior consultant with Young & Associates Inc. (younginc.com), with over 40 years of experience in compliance consulting, advising and assisting financial institutions on consumer compliance and compliance management issues. He has also developed and conducted compliance training programs for individual banks and their trade associations and has authored or co-authored numerous compliance publications and articles. Bill can be reached at (330) 678-0524 or wshowalter@younginc.com. Community Banker 19
Join Us at the MIB Griz Tailgate! SATURDAY, SEPTEMBER 12 Kirkland Memorial Grove, Spot #18 Tailgate at 11:00 a.m. | Kickoff at 1:00 p.m. Join MIB members near Washington Grizzly Stadium in Missoula for our annual Griz Tailgate ahead of an exciting matchup with the Utah Tech Trailblazers! Food and drink will be provided, and families and friends are welcome. We hope to see you there! 20 Community Banker
Established in 1980, Bankers’ Bank of the West has been serving community banks for over 45 years as a trusted, non-competing partner, grounded in strong relationships, industry expertise, and a long-term perspective. As the financial landscape continues to evolve, we remain focused on helping our partners stay relevant and competitive through purposeful innovation, operational efficiency, and responsive, experienced support, while staying true to the core values that have guided us since the beginning. EXPERT LOAN REVIEW SERVICES • Independent loan reviews. • Strategic growth consulting. • Helping banks strengthen credit quality, manage risk, and plan confidently for expansion and succession. • Community banks deserve a partner as dependable and resilient as the communities they serve. • Assessing wire transfer risks • Delivering compliant backup solutions. • Trusted support, expert guidance, and service every step of the way. BUSINESS CONTINUITY OPTIONS ASK US ABOUT BRIDGE! Our secure online portal for ACH, wires, reporting, OFAC screening, anomaly detection, SFTP, file transfers, and seven-year archiving. Bill Mitchell BBWest, CEO & Vice Chair Jim Swanson President, Bank Strategies, LLC. Anne Benigsen President, CivITas Bank Solutions, LLC. EST 1980 OVER 45 YEARS OF EXPERTISE We Champion Community Banking! 800-873-4722 | NE: 888-467-5544 | www.bbwest.com • Vulnerability scans. • Penetration testing. • Phishing simulations and IT consulting. • Plus, monitoring and training. • Policy reviews. • Board advisory support to strengthen your bank’s security posture. COMPREHENSIVE CYBERSECURITY SERVICES
6 Community Banking Wins in the First 6 Months of 2026 By REBECA ROMERO RAINEY, President and CEO, ICBA following last year’s transformative year in community banking advocacy, marked by significant tax and regulatory relief, ICBA and community bankers entered 2026 prepared for a more challenging political landscape. While the community banking industry has continued to achieve historic policy successes during the first half of this year, the current environment has nonetheless required forceful pushback from ICBA and our grassroots advocates. Here are six key community bank policy successes of the first six months of 2026 — as well as the priority issues that will continue to demand strenuous advocacy outreach during the second half of the year. THE INDUSTRY’S LANDMARK POLICY SUCCESSES 1. The 1071 Final Rule’s Community Bank Exemptions Aligning with ICBA’s years-long advocacy on the CFPB’s small-business reporting requirements, the bureau’s final rule exempts the vast majority of community banks, while we continue working to address the underlying 1071 statute in Congress. 2. Regulatory Relief Legislation Congress has made significant progress on statutory relief, with the House-passed ROAD to Housing Act addressing custodial and reciprocal deposits, the exam cycle, de novo applications and more. On the heels of a successful ICBA Capital Summit featuring more than 300 meetings with congressional offices, we continue working to get this bill through the Senate while advancing the significant relief included in the committee-passed Main Street Capital Access Act, FAIR Exams Act and TAILOR Act. 3. Ongoing Relief at the Agencies While last year’s success on overturning overdraft restrictions, raising audit and reporting thresholds, reducing BSA/AML burdens, and more set a high bar, ICBA has not let up on the gas this year in advocating before the banking agencies. An ICBA-supported final rule codifies the elimination of reputation risk from regulators’ supervisory programs, and the FDIC and OCC are working to establish independent supervisory appeals offices. With a March executive order directing agencies to consider additional reforms, including changes to CFPB mortgage rules and Home Mortgage Disclosure Act data collection and disclosure standards, we are working to obtain additional relief this year. 4. Capital Relief Through Lower CBLR In addition to reg relief, regulators enacted capital relief via a final rule that reduces the Community Bank Leverage Ratio from 9% to 8%, as long advocated by ICBA. Meanwhile, we continue supporting legislation to lower the CBLR to a range of 6-8% and authorize its use by banks with up to $15 billion in assets. 5. Farm Bill Passage This year’s passage of the Farm, Food, and National Security Act in the House is an important step toward completing a new farm bill. It builds on last year’s enactment of the ICBA-advocated ACRE Act policy that makes 25% of interest income on agriculture and ranch real estate loans exempt from federal taxation, though we’ll continue opposing any expansion of the Farm Credit System’s authorities to engage in non-farm financing. 6. Cracking Down on Cybercrime and Fraud President Donald Trump’s Cyber Strategy for America and executive order on combating cybercrime, fraud, and predatory schemes represent a much-needed commitment to hardening our financial and digital 22 Community Banker
systems against cyber threats, while sustained advocacy has led to progress in the battle against check fraud. With artificial intelligence raising new vulnerabilities, ICBA engaged with the White House and secured invitations to meetings to discuss new AI threats that had previously been extended only to the largest financial institutions. ICBA has also engaged the Treasury Department, Project Glasswing participants, community bank vendors and other organizations while releasing a new Community Bank AI Security Readiness Guide to help community banks navigate the current threat landscape. KEY CHALLENGES REMAIN 1. Threats From Stablecoin Yield and Nonbank Entities The current favorable environment for digital assets platforms and other nonbank competitors seeking bank-like powers without bank-like regulation has led to all-hands-on-deck battles over stablecoin yield, Federal Reserve master account access, and the OCC’s redefined national bank trust charters — with a new ICBA advocacy campaign warning of the risks posed by the crypto sector’s unpopular push for less accountability. While we push for a stronger prohibition on payment stablecoins’ ability to pay interest and yield as the debate over the CLARITY Act continues, we are urging policymakers to pause new policies on these issue areas to ensure “like risk, like regulation” for nonbank entities. We also continue to push back against the FDIC’s approval of new industrial loan companies from Edward Jones, Stellantis and others, while working to advance bipartisan Senate legislation to close the ILC loophole. 2. Keeping up the Push for Credit Union Parity We’ve seen growing interest among policymakers in the credit union tax exemption in recent years, including an ICBA-supported National Credit Union Administration proposal to facilitate credit union conversions to mutual banks, which aligns with our guide to conversion. To keep up the momentum, this year we unveiled our “Illusionists” advocacy and marketing campaign to pull back the curtain on growth-obsessed credit unions, complementing our data analysis on how credit union acquisitions of community banks are harming local communities. 3. Defending CDFIs Amid a Treasury Department review of community development financial institutions and ongoing challenges to the CDFI Fund’s budget, ICBA has worked hard to address these political pressures and ensure policymakers understand the role of these institutions in serving local communities. While policymakers have released withheld 2025 funding and fully funded the CDFI Fund for 2026, ongoing engagement on this critical sector will remain essential. 4. The Threat of Credit Card Restrictions Despite repeated success in fighting off Durbin-Marshall credit card routing mandates and misguided efforts to impose a credit card rate cap, these threats remain at the federal and state levels. ICBA and state community banking groups have commended Colorado’s veto of an unworkable interchange law, supported the Illinois General Assembly’s vote to delay its misguided law by another year and backed OCC efforts to preempt state restrictions. We will keep fighting federal and state threats to community bank credit card services. THE WAY FORWARD With our industry facing these high-stakes challenges every day, we will have to remain connected and fully engaged to ensure success. But in reviewing our latest advocacy wins — some of which required years of hard work — we see a track record of strength and achievement that we can sustain through the second half of this year. Thank you for all you have done to move the ball forward on so many critical issues. And let’s keep up the hard work to ensure our industry can continue helping Main Street communities thrive. Rebeca Romero Rainey is president and CEO of ICBA. Community Banker 23
The Threshold of Life Memorial The Threshold of Life Memorial reflects Montana’s strong culture of donation and service. Currently, 86% of Montanans are registered organ donors — significantly higher than the national average. The memorial aims to honor that legacy and the donors, both the living and those who, in their passing, gave the gift of life. The planned memorial is a unique and special project of statewide significance to honor all of Montana’s organ, eye and tissue donors. It stands as a beacon of hope for those awaiting lifesaving transplants and celebrates the lives of all individuals impacted by organ donation from every corner of Montana. Designed by Bozeman-based architect Ken VanDeWalle and approved by the 2023 Montana State Legislature, the planned memorial will be located on the grounds of the State Capitol. In accordance with House Bill 585, the cost of the memorial’s procurement, installation and maintenance must be paid from private funds. In order to complete the memorial, the Montana Governor’s Office of Community Service has partnered with the Helena Area Community Foundation, a 501(c)(3), to serve as the fiscal sponsor for this project. They are actively raising the $500,000 needed for the project. “Through the Threshold of Life Memorial, we will give hope to those awaiting lifesaving transplants while celebrating the lives of those impacted by organ donation,” Gov. Greg Gianforte stated. “May we all be reminded and thankful for donors who give the ultimate gift and be encouraged to support the memorial that will honor their lives.” In addition to fundraising for the Threshold of Life Memorial, Donate Life Montana is proud to announce the release of its new license plate design. A portion of the proceeds from each plate will go toward the memorial fund and help support educational and outreach efforts on organ, eye and tissue donation. Scan the QR code to make a donation to the Threshold of Life Memorial Fund. https://secure.qgiv.com/for/ thresholdoflifememorial/ Has your life been touched by organ, eye or tissue donation? Scan the QR code to share your story. https://www.surveymonkey.com/ r/tributestories Visit the Montana Department of Motor Vehicles and learn more about the new license plate by scanning the QR code. https://mvdmt.gov/portfolioitem/serve-montana-donate-life/ Get the latest updates by following the Threshold of Life Memorial on Facebook. https://www.facebook.com/ profile.php?id=61579712368717 How You Can Support Montana’s Organ and Tissue Donors 24 Community Banker
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