2026 ISSUE 2 OFFICIAL PUBLICATION OF THE NEBRASKA BANKERS ASSOCIATION Meet Travis Sears 2026-2027 NBA Chair
233 S. 13th St., Ste. 700 Lincoln, NE 68508 Phone: (402) 474-1555 • Fax: (402) 474-2946 www.nebankers.org EDITORIAL STAFF RICHARD BAIER President & CEO richard.baier@nebankers.org GISELA JUNDT Director of Communications & Marketing gisela.jundt@nebankers.org BOARD OF DIRECTORS TRAVIS SEARS NBA Chair Union Bank & Trust Co., Lincoln SCOTT ZIMBELMAN NBA Chair-Elect Homestead Bank, Cozad MARK LINVILLE NBA Past Chair First State Bank, Randolph KRISTY BARTAK Nebraska State Bank & Trust Co. Broken Bow NICK BAXTER First National Bank of Omaha Omaha THOMAS CORRIGAN ACCESSbank Omaha KRYSTI CUNNINGHAM Security National Bank of Omaha Omaha JASON HANSEN Associated Bank Omaha CURTIS HEAPY Western Nebraska Bank Curtis ZAC HOLOCH Cornerstone Bank York JEFF KANGER First State Bank Nebraska Lincoln KRISTEN MARSHALL-MASER Five Points Bank Grand Island JEREMY McHUGH Corn Growers State Bank Murdock AARON OTTEN Elkhorn Valley Bank & Trust Norfolk KEVIN POSTIER Henderson State Bank Henderson LUKE RICKERTSEN Flatwater Bank Gothenburg BRIAN SCHWEIGER U.S. Bank, N.A. Lincoln RYNE SEAMAN Cattle Bank & Trust Seward RYAN STEFFENSMEIER First Community Bank Beemer KELLY TRAMBLY South Central State Bank Campbell NICK VRBA RVR Bank Fremont MICHAEL WHEELER Wells Fargo Bank, N.A. Omaha ANDREW WITT Dundee Bank Omaha NBA 800.228.2581 MHM.INC Now more than ever people want self-service options. With our core integrated ITMs we can make this a reality both in the lobby and in the drive-up of your branch. SELF-SERVICE BANKING 4 NEBRASKA BANKER
BETTERTOOLS SERVICE BANKING Call Tim or Travis today to find out how much you could save. Why do community banks make the switch to MIB? Innovation & Technology: We continually enhance our services through a forwardthinking tech culture and strategic investments. User-Friendly Systems: Intuitive systems and easy-to-use services save customers time, effort, and stress. Superior Service: We go above and beyond—our experts will even visit onsite during service transitions. Operational Efficiency: Streamlined operations allow us to offer high-value services at highly competitive prices. mibanc.com MEMBER FDIC Lending Services Operational Services Audit Services* Tim Burns 402-480-0075 Travis Anderson 402-440-2448 * Audit Services are offered thru MIB Banc Services, LLC, a subsidiary of our holding company.
EDITORIAL: Nebraska Banker seeks to provide news and information relevant to Nebraska and other news and information of direct interest to members of the Nebraska Bankers Association. Statement of fact and opinion are made on the responsibility of the authors alone and do not represent the opinion or endorsement of the NBA. Articles may be reproduced with written permission only. ADVERTISEMENTS: The publication of advertisements does not necessarily represent endorsement of those products or services by the NBA. The editor reserves the right to refuse any advertisement. SUBSCRIPTION: Subscription to the magazine, which began bimonthly publication in May 2006, is included in membership fees to the NBA. ©2026 The Nebraska Bankers Association (NBA) | MBR Connect, formerly The newsLINK Group LLC. All rights reserved. Nebraska Banker is published six 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 NBA, 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. Nebraska Banker is a collective work, and as such, some articles are submitted by authors who are independent of NBA. 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. CONTENTS 14 24 8 MEET TRAVIS SEARS 2026-2027 NBA Chair Laurie Johnson, Nebraska Bankers Association Staff 12 WASHINGTON UPDATE BANKING CAN BRIDGE THE POLITICAL DIVIDE Rob Nichols, President and CEO, American Bankers Association 14 TECH TALK CONFESSIONS OF A CYBERSECURITY PRO WHO FAILED A PHISHING TEST Julia Miller, Marketing Manager, SBS CyberSecurity 18 COUNSELOR’S CORNER SOVEREIGN CITIZENS AND DEBT-AVOIDANCE INDICATORS Steven M. Winston, Baird Holm LLP 22 PENNIES NO LONGER IN PRODUCTION IMPACT CASH TRANSACTIONS AND SALES TAXES Lance Jacobs, Managing Director, and Natalie Straus, CRCM, Director, Forvis Mazars 24 TRANSFORMING COMPLIANCE TRAINING From Obligation to Engagement Laurie Rowe, CRCM, Virtual Compliance Office | Virtual Partners, Compliance Alliance 26 COMMUNITY BANKS AND CRYPTO-ASSETS Is It Time To Start Exploring? Ian F. McDowell, CPA, Principal, Audit and Assurance, S.R. Snodgrass PC 31 2026 EDUCATION CALENDAR 6 NEBRASKA BANKER
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Anyone who has been in the banking industry for over 30 years can tell you that a lot has changed in that time. From new operations processes and technologies to a wider range of ways to interact with banks, the business of banking evolves a little more every day. But one thing hasn’t changed: relationships between bankers and customers that are built on trust. For 2026-2027 Nebraska Bankers Association Chair Travis Sears, relationship building has been a constant throughout his career and remains foundational to his role as vice president of operations at Union Bank & Trust. Meet Travis Sears 2026-2027 NBA Chair Laurie Johnson Nebraska Bankers Association Staff “I think people trust banks like they did back then. It’s based on relationships and how bankers connect with customers to serve their financial needs. People still want to come in and have that conversation with a banker,” Sears said. Beginnings in Banking Relationships played a significant role in Sears’ early entry into the banking world. Leaning on an existing connection to a local branch manager, at 18 years old, he began working for the National Bank of Commerce as a night and weekend ATM repairman while attending the University 8 NEBRASKA BANKER
of Nebraska-Lincoln, shortly after graduating from Crete High School. After transferring to Concordia University and switching his major from business education to business management, Sears maintained a full-time role at the bank. One of Sears’ roles early in his career (circa 1993) was helping with bank conversions and starting a debit card center. Very few banks offered them at the time; most had only a credit card or an ATM-specific card. That role allowed Sears to strengthen his relationship-building skills; he connected with multiple banks and helped set them up in the debit card system, which combined ATM and point-of-sale functionality for added flexibility. Then, in 1996, Union Bank & Trust offered him a job as a supervisor in the Lincoln area, and the rest is history. Now, three decades later, Sears and his wife Jackie — whom he met while working his first bank job — call Lincoln home. Throughout his career, Sears said the biggest change in the banking industry has been the pace of technological change. Before, physical bank branches served as the main point of interaction between bankers and customers. Now, there are bank branches, online banking, text alerts and more, all evolving to meet varied customer preferences and needs. “There’s new technology coming out all the time. It’s a constant change now, where before the adoption of new technologies was very slow. I think it’s better for the consumers now that they have more choices about where and how they want to do their banking,” Sears said. From left: Scott Zimbelman, Homestead Bank (Cozad), NBA Chair-Elect; Mark Linville, First State Bank (Randolph), NBA Past Chair; Travis Sears, Union Bank & Trust (Lincoln), NBA Chair; and Richard Baier, NBA President & CEO 9 NEBRASKA BANKER
Connecting Communities In his role at UBT, Sears has found the most rewarding part to be the relationships he has built and continues to build with customers. He also enjoys strengthening connections with the bank’s team, watching coworkers bloom and advance to management. But Sears doesn’t just make time for customers and coworkers; he makes giving back to his community a priority. “UBT encourages all employees to volunteer and offers many opportunities to do so, from hosting shred days at the bank to boxing up food for kids at school and more. It’s important to support your community,” Sears said. “If you have a thriving community, there’s a good chance at least one bank is there.” Sears recognizes that while banks provide a variety of services, their main purpose is to support people. He believes banks’ role is to help individuals achieve their dreams through financial planning and lending for major purchases or life events. “No matter the size of the bank, they all provide the same basic services — financial support and guidance — to the communities they serve. When the banking system comes together, the whole system becomes stronger,” Sears said. Goals as Chair In his role as NBA chair, Sears is excited to help industry members support one another as he gets to know bankers from across Nebraska. He’s looking forward to hearing from NBA members about what is and isn’t working across banks of all sizes in order to help them thrive. Travis Sears (left) and Mark Linville Travis Sears and Mark Linville at Husker Harvest Days in 2025 Additionally, he plans to help develop new ways to fight fraud across the industry, including furthering the NBA’s anti-fraud initiatives, such as the Fraud Free Nebraska Coalition and the new “That’s a Red Flag” scam awareness and prevention campaign (thatsaredflag.com). Sears also plans to keep an eye on federal banking regulations and to encourage regulatory reform to make it easier for banks to provide what their communities need without all the “red tape.” “Right now, we’re facing increasing pressure from the regulatory environment, a rise in fraud and a need to constantly adapt in how we serve our communities. But one thing is clear — we’re stronger when we face these issues together,” Sears said. “No bank should be out there on an island. Our ability to collaborate is one of our greatest strengths.” Mentoring the Next Generation Prior to becoming NBA chair, Sears gained experience volunteering in leadership roles within the NBA, including serving on various committees and the board of directors. He is also a graduate of the KBA/NBA Advanced School of Banking and the Operations School. Sears credits various teachers, mentors and role models for shaping his view on leadership and community focus. Sears hopes to give back to the industry that has given him so much over the years. For those considering a career in banking, he encourages them to apply at their local bank and gain exposure to the various positions within the industry. According to Sears, being a banker is so much more than a job; it’s a career, whether you’re a teller, IT person, lender, marketer or something else. “If you’re good at building relationships, there are endless opportunities within banking,” Sears says. 10 NEBRASKA BANKER
More About Travis Travis Sears has served on the Nebraska Bankers Association Board of Directors, its Executive, BankPAC and Education Advisory Operations Committees and the Dues Task Force. Other financial industry experience includes serving on user councils for NetWorks, EPCOR and Accel (Fiserv) payments. An avid learner, he has also participated in programs through the KBA/NBA Schools of Banking. At the local level, Sears has served on the Crete Volunteer Fire Department, the Crete City Council and the Nebraska Safety Council Board of Directors. He gives back to his community through various volunteer roles with his church, the local food bank, CEDARS Youth Services and the Knights of Columbus. Outside of banking, Sears enjoys spending time with his children and grandchildren. He also loves the outdoors, whether fishing at the lake, golfing, hunting or chasing cows at the ranch. Travis Sears delivers remarks as the new NBA Chair at the 2026 Annual Convention. 11 NEBRASKA BANKER
WASHINGTON UPDATE Banking Can Bridge the Political Divide Rob Nichols, President and CEO American Bankers Association 12 NEBRASKA BANKER
We all recognize the political divisions in this country and the difficulty in getting Republicans and Democrats to agree on the time of day, much less substantive policy issues. But as bankers who attended ABA’s recent Washington Summit in the nation’s capital learned, once you drill down past the headlines and the noise on cable news shows, you’ll find that not only is bipartisan cooperation still possible when it comes to banking — it’s happening. During the Summit, bankers had the opportunity to hear from lawmakers on both sides of the aisle, and what came across consistently was a commitment to ensuring that we have a strong, resilient banking sector that encourages economic growth and helps consumers and businesses thrive and prosper. As freshman Sen. Angela Alsobrooks (D-MD) — who has emerged as a bipartisan dealmaker in her first several months on the job — observed on the Summit stage, “Our varying backgrounds often color how we see things, but that doesn’t mean we can’t come together and do great things.” At ABA, we agree with this statement — in fact, it’s been the bedrock of our approach to advocacy over the years. And if you look at the current session of Congress, you’ll see several examples of bipartisan cooperation on banking issues. One great example is the SCAM Act that is currently moving through both chambers of Congress, co-sponsored by Sens. Ruben Gallego (D-AZ) and Bernie Moreno (R-OH) in the Senate and Reps. Lou Correa (D-CA) and Dan Meuser (R-PA) in the House. This bill, which has strong support from both ABA and the state associations, takes aim at the widespread problem of fraud perpetrated through social media. The bill requires companies like Meta to take reasonable steps to identify and remove fraudulent ads from their platforms since we know that’s where so many scams start. The support for this bill from both sides of the aisle is a clear indication that lawmakers recognize the need to respond to the fraud crisis facing Americans. The SCAM Act is a commonsense solution that will protect American consumers, and we’re working hard to ensure it becomes law. Please support this effort by visiting aba.com/takeaction and urging your lawmakers to co-sponsor the bill today. Members of Congress in both parties have also come together in recent days on housing reform legislation, as well as bills that would make it easier for banks to access Federal Home Loan Bank resources to help fund community development projects, increase asset thresholds to make it easier for banks to qualify for an 18-month exam cycle and crack down on credit repair scams. I say it often: The intermediation of capital, improving access to housing, as well as the protection of Americans from growing threats like fraud and scams, aren’t Democratic issues or Republican issues. They’re American issues. At ABA, our longstanding approach to advocacy has always been — and will remain — militantly bipartisan, and throughout much of our nation’s history, banking issues remained above the political fray. I don’t know if we can ever return to that, but we will continue to work with anyone in Washington — regardless of party — who appreciates the critical role America’s banks play in the country and shares our view that all Americans benefit from a clear, consistent bank policy environment that promotes economic growth and prosperity for all. Email Rob at nichols@aba.com. At ABA, our longstanding approach to advocacy has always been — and will remain — militantly bipartisan, and throughout much of our nation’s history, banking issues remained above the political fray. 13 NEBRASKA BANKER
TECH TALK Confessions of a Cybersecurity Pro WHO FAILED A PHISHING TEST I considered agreeing to a post-phish interview only if the lights were dim, my voice was gravelly, and my silhouette appeared in profile, like an anonymous source in a documentary about international espionage. Picture it: The camera pans across the darkened room, my identity shrouded in mystery as I confess, “Yes, it’s true. I clicked on a phishing email. I did the thing. Please, never show my face to the IT department again.” All that was missing was dramatic background music and an on-screen subtitle: “Phishing Victim, Security Professional.” But there’s power in stepping out of the shadows and owning these moments, no matter how mortifying. We build resilience not by pretending mistakes don’t happen, but by recognizing they can happen to anyone, at any time. It’s through sharing our stories, stripped of anonymity and shame, that we foster understanding and collective vigilance. The Value of Regular Phishing Assessments Before I recount the moment I fell for the bait, it’s worth reflecting on why companies conduct phishing assessments in the first place. No amount of training alone can guarantee immunity, as hackers are always adapting. That’s why organizations, mine included, have made regular phishing simulations a cornerstone of their security strategy. These tests aren’t meant to embarrass or punish. Instead, they serve as real-world reality checks, revealing subtle vulnerabilities that creep in when we least expect them. Routine phishing tests help employees practice vigilance safely, sharpen their instincts and keep everyone alert to the latest tactics. Every misstep becomes a learning moment, cultivating a culture where cybersecurity is everyone’s responsibility. Julia Miller, Marketing Manager SBS CyberSecurity 14 NEBRASKA BANKER
The Email That Got Me It was a Tuesday morning like any other, with coffee in hand, to-do list ready and a fresh batch of emails to sort through. As a long-time cybersecurity professional, I like to think I’m savvy about spotting suspicious messages. I’ve written about phishing, warned others, passed dozens of phishing tests, completed security awareness training and even helped design campaigns. But that morning? That morning, I clicked. It wasn’t flashy. No Nigerian prince. No lottery winnings. Just a simple, well-crafted email with the subject line: “Executive/HR Meeting Report.” The message contained a link to a document from my manager — a typical red flag. However, I had just completed my annual review, and my manager was going to send compensation notes along with a final document for me to sign. I was eagerly awaiting that email. The timing couldn’t have been better — or worse. In my haste, I didn’t scrutinize as closely as I should have. The sense of importance, paired with familiarity, made it feel legitimate. Click. Bam! A splash screen: “Oops! You clicked on a simulated phishing test!” Cue the facepalm. The Aftermath I shook my head. I groaned. I may have said, “Well played, security team.” Mostly, I was just surprised. How did I fall for that? Phishing isn’t always obvious anymore. Today’s attacks are subtle, familiar and timed to catch you off guard. The answer is simple: I was moving too fast and didn’t follow the Golden Rule of email — treat every email as if it’s a phishing attempt. The Golden Rule in Action Phishing isn’t always obvious anymore. Today’s attacks are subtle, familiar and timed to catch you off guard. This email looked like it came from my manager. It referred to a document I was expecting. It had just enough familiarity to override my better judgment. The Golden Rule encourages us to slow down and ask: • Who is this really from? • What are they asking me to do? • Why am I getting this now? • Does this make sense? If I had paused to hover over the link or double-check the sender, I’d have seen the red flags. But I didn’t. Here’s the breakdown of this scenario: • Who is this really from? The sender’s address didn’t exactly match my manager’s or HR department’s usual address. • What are they asking me to do? They wanted me to open and review a document. I was expecting one, just not in this delivery method. • Why am I getting this now? I was expecting a document when the phishing email was sent, which made it feel legitimate. • Does this make sense? This is where I tripped up. I should have put the first two red flags together and realized that, while I was expecting a document, it wouldn’t be sent in this format. Even the tiniest lapse — a split second of inattention — could spell major trouble. One careless click could expose sensitive data, trigger a costly breach and affect everyone relying on our systems. I’m genuinely grateful this was a test, not a real attack. It’s a wake-up call and a timely reminder that vigilance isn’t optional. It’s essential. 15 NEBRASKA BANKER
What to Do If You Click on a Phishing Link Even experienced employees can accidentally click on a phishing email, but what matters most is how you respond. Whether it’s a test or a real attack, here’s what to do if you click on a phishing link. If you’ve clicked on a phishing test, take a breath — it’s a learning opportunity, not a failure. • Don’t panic. These tests exist to help you recognize patterns and improve. • Take a moment to review what made the email convincing. • Report your click if your company tracks test results. Transparency helps improve training. • Apply what you learned so you’re ready if a real phishing attempt lands in your inbox. If you’ve clicked on a real phishing email, speed matters. • Disconnect from the network if possible. • Alert your IT or security team immediately so they can contain potential risks. • Change any passwords you entered, or that might have been exposed. • Keep an eye on your accounts for unusual activity or login attempts. • Follow any additional steps your IT team recommends for incident response. By responding quickly — and honestly — you help protect your organization and turn a stressful moment into a valuable lesson. What I Learned After the embarrassment wore off, I shared my experience with the team. If I can fall for it, anyone can. The point of phishing tests is to train, not shame. Now, every email gets my attention. I slow down, hover, verify, ask questions and remind myself that even the best of us need reminders. Cybersecurity isn’t just about firewalls and filters — it’s about people. This article was originally published on sbscyber.com. SBS helps business leaders identify and understand cybersecurity risks to make more informed and proactive business decisions. For more information, contact Julia Miller at julia.miller@sbscyber.com. 16 NEBRASKA BANKER
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Although only a small segment of the American population, sovereign citizens have managed to cause significant headaches for commercial lenders over the past several decades. While their primary antagonists are typically government agencies, sovereign citizens have developed a host of pseudo‑legal theories and tactics aimed squarely at avoiding private debts and obstructing creditors. This article provides lenders with a clear overview of core sovereign citizen beliefs and highlights common documentary indicators that a prospective or current borrower may subscribe to this ideology. Who Are Sovereign Citizens? “Sovereign citizen” is a broad and imprecise label encompassing an ideologically diverse range of individuals and groups who share one foundational belief: that the United States government, as presently constituted, is illegitimate and lacks authority over them.1 The most commonly held sovereign citizen beliefs rest on a distorted understanding of American history centered around two dates: 1868 and 1933. In 1868, adherents believed that the passage of the Fourteenth Amendment created two classes of citizens: (1) “de jure” citizens governed only by what they call “common law,” and (2) “federal commercial citizens,” who are allegedly subject to illegitimate federal authority.2 Sovereign citizens believe, by some artifice or another, that they are or have become de jure citizens and thus are exempt from statutes and regulations, and the Uniform Commercial Code (UCC).3 Second, in 1933, sovereign citizens contend that the United States declared bankruptcy when it abandoned the gold standard.4 In their understanding, in place of the gold standard, the federal government created separate “strawman” identities for every American at birth linked to secret United States Treasury accounts, which contain vast sums of money — sums of money that the government now uses as collateral.5 The strawman identity, they claim, is signaled by the appearance of the person’s name in ALL CAPITAL LETTERS on government documents and financial instruments.6 Through use of the correct pseudo-legal language or document rituals, sovereign citizens believe that: (1) they can access the funds in these imaginary strawman accounts and (2) any debt, contract or legal obligation only binds their strawman identity, not their real “flesh-and-blood” self.7 While adherents come from all walks of life, this ideology particularly attracts individuals experiencing severe financial distress or extreme frustration with government or banking institutions. For lenders, the practical risk is immediate: Sovereign citizens can increase servicing costs, create friction in default proceedings, disrupt collections and occasionally pose safety concerns for frontline staff. Recognizing early indicators can significantly reduce these risks. COUNSELOR’S CORNER Sovereign Citizens and Debt-Avoidance Indicators Steven M. Winston, Baird Holm LLP 18 NEBRASKA BANKER
How Sovereign Citizens Try to Avoid Private Debt Collection Sovereign citizens employ a variety of schemes to frustrate the enforcement of valid loan obligations. Two of the most common involve: (1) challenging the validity of the original loan agreement because it binds only the strawman and not the “flesh-and-blood” person; and (2) attempting to discharge debt through pseudo-legal inscriptions, often referred to as “Accepted for Value” (A4V) schemes. Denying the Contract’s Validity A frequently used tactic is asserting that the borrower signed the agreement only as an agent for their strawman identity and therefore did not personally consent to the contract.8 Under this theory, only the fictional entity is bound by the loan. Some also argue that because all contracts are governed by the UCC, and because they are “de jure” citizens, all contracts are unenforceable against them.9 “Accepted for Value” (A4V) Schemes In A4V schemes, sovereign citizens attempt to “pay” debts using specific inscriptions, stamps or phrases that they believe activate their strawman’s Treasury account or serve as alternative contractual consideration.10 The most recognizable is “Accepted for Value,” but sovereign citizens deploy a wide range of pseudo‑legal phrases. When used, adherents believe that a binding contract is automatically created upon the lender’s receipt of the inscribed documents.11 Depending on their interpretation, sovereign citizens believe that this scheme results in one of two outcomes. First, adherents may believe that the inscribed document forces the lender to satisfy the debt by withdrawing funds from their strawman’s secret Treasury account.12 Alternatively, adherents believe that if these phrases are used in conjunction with postage stamps affixed to the document, the stamp itself becomes an adequate substitute consideration that satisfies the debt upon receipt.13 Neither of these schemes has any legal validity. Regardless, lenders should learn to recognize the indicators signifying when sovereign citizens are attempting to employ them so that the issue can be promptly escalated to legal counsel. Sovereign Citizen Indicators: What Lenders Should Watch For The good news is that sovereign citizens tend to announce themselves through distinctive markings, formats or inscriptions on documents. The following indicators are among (but not all of) the most common. Postage Stamps Affixed to Documents Affixing postage stamps to loan documents is one of the clearest red flags. Sovereign citizens (incorrectly) believe that affixing these stamps transforms their documents into protected “correspondence” and thus prevents any United States government from exercising jurisdiction over them.14 Sovereign citizens employ a variety of schemes to frustrate the enforcement of valid loan obligations. 19 NEBRASKA BANKER
Additionally (or alternatively), adherents contend that the postage stamp itself constitutes binding consideration in lieu of repayment of the underlying loan.15 Regardless of the specific rationale, mainstream borrowers do not engage in this behavior; its presence should be treated as a significant warning sign that the borrower is a sovereign citizen. ALL CAPS or Unconventional Name Formatting Another common indicator is when the borrower signs their name in all capital letters (JOHN DOE), formatted with unusual punctuation (Doe;. John) or both (DOE;. JOHN).16 By signing the document in this manner, sovereign citizens believe that they have properly differentiated their “flesh-and-blood” selves from their strawman identity and that any signature they provide is as an agent for the strawman.17 Accordingly, to them, any agreement signed in such a manner is not binding upon their flesh-and-blood self.18 Although such formatting occasionally results from a confused but well-meaning borrower, these signatures should prompt heightened awareness from lenders, as they may indicate the borrower’s subscription to the sovereign citizen ideology. “Without Recourse” and “Without Prejudice” Language Perhaps the most widely used documentary marker is the addition of “Without Prejudice” and “Without Recourse” near or within the signature block. They believe these statements create a record that the sovereign signed under protest, did not consent to the court’s or lender’s authority, and cannot be held personally liable.19 While sovereign citizens draw these statements directly from UCC §1-308, they distort their meaning far beyond any legitimate interpretations, like magic talismans that protect those who invoke the phrases from any government jurisdiction.20 The presence of these phrases near a signature block should be treated as a strong indicator of sovereign citizen ideology. This is an anonymized recreation of a loan document Baird Holm LLP received, which depicts some of the symbols sovereign citizens use to attempt to avoid paying debts. Using this article as a reference, see how many red flags you can identify. Conclusion Although courts have uniformly rejected every sovereign citizen theory and scheme just described, these tactics remain disruptive and costly for lenders. Early identification is the most effective way for lending institutions to limit the expenses and threats created by sovereign citizens. By training frontline employees to recognize the indicators outlined in this article and to escalate promptly to legal counsel, lenders can better manage the risks posed by this small but ever-present menace at the fringes of American society. 1 A Quick Guide to Sovereign Citizens 1, UNC Sch. of Gov’t (rev. Nov. 2013), https://www.sog.unc.edu/sites/www.sog.unc.edu/files/Sov%20citizens%20 quick%20guide%20Nov%2013.pdf. 2 Id. at 1–2. 3 J.M. Berger, Without Prejudice: What Sovereign Citizens Believe 4–5, G.W.U. Program on Extremism (June 2016), https://extremism.gwu.edu/sites/g/files/ zaxdzs5746/files/downloads/JMB%20Sovereign%20Citizens.pdf. 4 FBI Domestic Terrorism Operations Unit II, Sovereign Citizens: An Introduction for Law Enforcement 6–7 (Nov. 2010) (unclassified/law enforcement sensitive). 5 Id. 6 Id. 7 Mellie Ligon, The Sovereign Citizen Movement: A Comparative Analysis with Similar Foreign Movements and Takeaways for the United States Judicial System, 35 Emory Int’l L. Rev. 297, 301–2 (2021). 8 Berger, supra note 3, at 5–6. 9 Id. 10 Anti-Defamation League, The Sovereign Citizen Movement: Common Documentary Identifiers & Examples 9–10 (2016). 11 Id. 12 FBI Domestic Terrorism Operations Unit II, supra note 4, at 6–7. 13 Donald J. Netolitzky, Organized Pseudolegal Commercial Arguments as Magic and Ceremony, 55 Alberta L. Rev. 1045, 1063–64 (2018). 14 Id. at 1058–59. 15 Id. at 1063–64. 16 Anti-Defamation League, supra note 10, at 2, 5. 17 Id. 18 Id. 19 Berger, supra note 3, at 5. 20 Anti-Defamation League, supra note 10, at 3. 20 NEBRASKA BANKER
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On Nov. 12, 2025, the last penny was minted at the U.S. Mint in Philadelphia. The U.S. Secretary of the Treasury exercised authority under 31 United States Code (USC), Section 5111(a) and §5112 to suspend production. The decision to cease penny production was largely rooted in cost. According to the U.S. Mint, the total production cost of the penny has risen from 1.42 cents to 3.69 cents per penny over the past 10 years. The U.S. Mint predicts the discontinuation of the penny will result in annual savings of $56 million. New pennies will no longer be manufactured, but according to the U.S. Department of the Treasury (Treasury), there are around 114 billion existing pennies in circulation. While the penny remains legal tender and may still be used for transactions, it is anticipated that the stoppage in production will reduce and eventually eliminate pennies in circulation. Federal Considerations The Federal Reserve is responsible for distributing coins to banks and credit unions. The Federal Reserve will still accept deposits of pennies from banks and credit unions; however, it indicates that the coin distribution locations accepting deposits will vary over time. Coin distribution locations will cease fulfilling penny orders when inventory is depleted.1 This will impact cash transactions, and it will be necessary to “round” such transactions in the absence of penny availability. Currently, there are no federal “rounding” guidelines. Pennies No Longer in Production Impact Cash Transactions and Sales Taxes Lance Jacobs, Managing Director, and Natalie Straus, CRCM, Director Forvis Mazars 22 NEBRASKA BANKER
On July 23, 2025, the Common Cents Act passed out of the House Committee on Financial Services on a bipartisan basis. The act proposes the following rounding practices for cash transactions only: • If the price ends in $0.01, $0.02, $0.06, or $0.07, round down to the nearest $0.05. • If the price ends in $0.03, $0.04, $0.08, or $0.09, round up to the nearest $0.05. • If the price is exactly $0.01 or $0.02, round up to $0.05.2 However, further consideration is required before the act can be advanced for floor votes.3 In the meantime, Treasury recognizes that “states will approach this issue differently based on unique considerations” and indicates “businesses should apply rounding practices in a fair, consistent and transparent manner.” Business Impacts While the penny still remains legal tender, businesses are expected to choose between several options to reflect this change: choosing to round cash transactions to the nearest nickel, requiring exact change (though the ability to do this will be limited as fewer pennies are in circulation) or using credit card or digital transactions. The cessation of penny production and the resulting decrease in the number of pennies in circulation have implications for cash transactions for retailers selling taxable products. Several states have addressed the implications of this for sales and use tax purposes. In addition to the various administrative pronouncements, several states, including Arizona, Florida, Missouri and Nebraska, have pending legislation to address these issues. 1 “Penny Order and Deposit Information,” frbservices.com, 2026. 2 “The Penny May End in 2026,” commoncentsact.com, 2026. 3 Ibid. 23 NEBRASKA BANKER
Compliance training is essential in banking, yet one of the greatest challenges for bank compliance officers is transforming this critical requirement from something that employees dread into an experience that is both engaging and effective. While the regulatory stakes are high and the material is often complex, the real test lies in helping employees not only complete the training but truly understand and apply it in their daily work. Creating that level of comprehension requires more than checking a box — it demands thoughtful design, meaningful delivery and a commitment to making compliance feel relevant rather than routine. Most of us think of compliance training as the assignments we receive every year through various learning platforms. These are usually in the form of webinars and come with a test at the end. This method of training serves an important purpose and carries significant value. It is an effective way to show auditors or examiners exactly what has been covered and how annual training expectations have been met, with clearly documented attendance records. To support this process, Compliance Alliance has introduced the Compliance Hub Task Manager — a streamlined tool that allows institutions to assign and track training, with an audit-ready history available whenever it’s needed. While this approach is important, it should not be the only method used for effective compliance training. True comprehension often requires more interactive, memorable experiences — elements that can make training not only more effective, but more enjoyable. Make Learning Interactive Everyone likes to play games. Introducing gaming elements, such as leaderboards and rewards, into compliance training can enhance engagement. Friendly competition among employees, real-time feedback and point-based achievements can make learning regulatory requirements more entertaining. Transforming Compliance Training From Obligation to Engagement Laurie Rowe, CRCM, Virtual Compliance Office | Virtual Partners Compliance Alliance A fun example I’ve seen is a bank-wide Olympic Games theme. Each employee was randomly assigned to a country and awarded medals for various compliance achievements. There was even an opening ceremony to kick off the compliance festivities and a closing ceremony to recognize those with the most gold medals. Create Real-World Scenarios Government regulations are far from easy to understand — even for compliance officers who work with them every day. When presented through real-world scenarios and case studies, complex regulations can become much easier to grasp. Case studies highlighting actual compliance successes and failures help employees relate key compliance issues to their daily job functions. These can be situations that have occurred at your own bank or examples you’ve learned about from other institutions. Detail the scenario and ask employees what they would do in that specific situation. They may have encountered it before and didn’t know how to react or respond — but now they will. Engaged employees are more likely to retain the critical compliance knowledge they need to perform their job functions effectively, reduce risk and protect the bank. 24 NEBRASKA BANKER
Initiate Immersive Training Experiences Engaging exercises such as role-playing and simulations give employees the opportunity to practice compliance scenarios in a safe environment. This hands-on approach can increase confidence and help ensure employees are prepared for real-life situations. These exercises can also be fun to set up. Have key bank leaders — such as the CEO or chief lending officer — play different customer roles and present questionable or “shady” transactions to frontline staff. The better they play the role, the more interesting and memorable the experience becomes. Incentives and Recognition Some employees thrive on recognition and will go the extra mile to earn it. Using certificates, email kudos or small rewards to highlight employees who excel in compliance training helps foster motivation. Public acknowledgment not only reinforces the importance of compliance but also encourages broader participation. A monthly email recognizing an employee who has gone above and beyond, or a gift card drawing limited to those who participated in extra training, are just a few simple ways to build momentum. To support effective compliance training and provide ideas for increasing engagement, Compliance Alliance offers several tools to help institutions build a strong program. These include live and previously recorded webinars covering a wide range of compliance topics, as well as Compliance Minutes — short, focused videos that break down key regulatory rules and requirements. Engaged employees are more likely to retain the critical compliance knowledge they need to perform their job functions effectively, reduce risk and protect the bank. By implementing one or more of these strategies, institutions can transform compliance training from a tedious obligation into a dynamic and effective educational journey. Your Full-Service Bankers' Bank United Bankers' Bank is proud to be the nation's first bankers' bank, serving over 1,000 community banks from the West Coast to the Great Lakes and South Atlantic. We can't wait to share our passion for community banking with you! To Request Pricing Visit ubbRequest.com Contact your Nebraska Calling Officer: Michael Hahn VP, Correspondent Banking Officer michael.hahn@ubb.com ubb.com 25 NEBRASKA BANKER
Community Banks and Crypto-Assets Is It Time To Start Exploring? Ian F. McDowell, CPA, Principal, Audit and Assurance S.R. Snodgrass PC Speaking recently with our many community bank clients, we’ve seen a significant increase in questions and concerns regarding the increased presence of crypto-assets business models. The general sentiment is “I know it’s being discussed, but I’m not sure how the regulators will view this or how it will affect the current operations of my community bank.” As these questions continue to increase, this article has been prepared to provide some insights into the FDIC’s current regulatory developments, as well as some practical information on how community banks can start to explore this topic at their own organization. Let’s start with how the regulatory landscape has changed over the last few years. Between April 2022 and March 2025, the FDIC issued two brief Financial Institution 26 NEBRASKA BANKER
Letters on this topic: FIL-16-2022 and FIL-7-2025. It doesn’t take much reading between the lines to identify an apparent shift from a precautionary, pre-notification stance on banks’ crypto-related activities (FIL-16-2022) to a permissions-based, risk-management stance that rescinds the prior notice requirement (FIL-7-2025). In the 2022 letter, the FDIC required banks to notify the agency before engaging in any crypto-related activity and emphasized evolving safety and soundness, consumer protection and financial stability risks. Following, in the 2025 letter, the FDIC affirmed that FDIC-supervised institutions may engage in permissible crypto-related activities without prior FDIC approval, provided risks are adequately managed and activities comply with applicable law. Additionally, in February 2025, the FDIC published 25 “pause letters,” which were sent to banks between October 2018 and January 2025, discussing the FDIC’s concerns with their crypto-related activities. In the context of the release, Acting FDIC Chairman Travis Hill commented about the FDIC’s position evolving to provide a pathway forward for banks by saying, “Looking forward, we are actively reevaluating our supervisory approach to crypto-related activities. This includes replacing Financial Institution Letter (FIL) 16-2022 and providing a pathway for institutions to engage in crypto- and blockchain-related activities while still adhering to safety-and-soundness principles.” Taking a slightly deeper look at the remarkably brief 2025 FIL, the following highlights are noteworthy: • Risk-Based Approach: The letter reiterates that banks must conduct all activities “safely and soundly and consistent with all applicable laws and regulations.” Risk areas called out include market/liquidity, operational and cyber, consumer-protection and AML. • How Permissibility Is Framed: FIL-72025 affirms that activities involving new and emerging technologies — including crypto-assets and digital assets — can be permissible if risks are managed. It references OCC interpretive letters on custody and stablecoin reserves as examples of activities that may be permissible when executed appropriately. • Forward-Looking Coordination: The FIL states the FDIC will work with other banking agencies to replace the 2023 interagency statements on crypto-asset risks and liquidity vulnerabilities with further guidance or regulations and continue engagement with the President’s Working Group on Digital Asset Markets. • Tone: The tone is notably pragmatic and enabling. The accompanying press release quotes Acting Chairman Travis Hill as saying the FDIC is “turning the page on the flawed approach of the past three years.” This signals a desire to provide a clearer path for banks to engage in crypto/blockchain activities under safety-and-soundness standards. Additionally, following on the heels of the FIL in March, Congress generated additional tailwind on the topic by signing the GENIUS Act into law. While the details of the GENIUS Act aren’t being discussed in this release, the Act generally defines and regulates stablecoins that are used for payments or settlements. At the time the Act was signed into law, whitehouse.gov described the Act by saying, “This long-overdue legislation creates the first-ever Federal regulatory system for stablecoins, ensuring their stability and trust through strong reserve requirements.” The Act goes a long way to promote more widespread use of stablecoins throughout the economic system while providing regulatory guardrails that a community bank must be familiar with when considering a crypto-friendly business model. With the apparent change in tone at the regulatory level, the question we hear most frequently is, “How are community banks getting involved with crypto-assets in practice?” While the short answer is that not many are, there are a few emerging topics that community banks 27 NEBRASKA BANKER
may want to consider if they want to start preparing for a crypto-friendly environment for their customers. Although the industry is still in its infancy with crypto-assets, there have been a few potential use cases at larger players like JPMorgan and Bank of America that have shown potential to possibly “trickle down” to the community banking space: • Custody Services: Offering custody services for your customers’ crypto-assets may align with some banks’ current Trust Services or Wealth Management divisions. In the early stages, a streamlined approach to this type of service may involve a mutual partnership with a third-party service where the bank acts as the custodian for the asset broker. This approach may be appealing to banks hoping to attract or retain younger customers who already hold crypto-assets but are unsure about the safety or security of the parties safeguarding those assets. • Stablecoin Reserves: Many crypto exchanges and fintech firms (River, for example) attract customers to their platform by holding client assets in full reserve, meaning that for every dollar invested in crypto-assets, they hold a dollar in a cash reserve with a qualified institution. This provides an opportunity for banks to be that institutional partner. With the passing of the GENIUS Act, we expect to see particular interest in stablecoin activity over the coming years. • Crypto-Backed Lending: As crypto-assets continue to become a larger part of consumers’ asset portfolios, customers may have an increased need to convert those less liquid assets into spendable dollars. While lending against direct crypto-asset holdings, such as bitcoin, is likely to be well outside the risk tolerance of most community banks, other crypto-related assets, such as publicly traded crypto-ETFs, may be a viable source of loan collateral; however, robust risk mitigation policies would need to be developed and implemented to ensure the safety and soundness of the activities. Any time a bank is venturing into uncharted territory, a slow, methodical approach is critical. The following are a few actionable insights to help a community bank explore crypto-related activities consistent with FIL-7-2025: • Start with activities that have clearer supervisory lineage. Consider crypto custody, stablecoin reserve services or participation in permissioned networks/INVN for payments — areas referenced by bank regulators and consistent with FIL-7-2025’s framing of potentially permissible activities. These business models also relate directly to the more robust guidance published by the OCC in interpretive letters 1170, 1172 and 1174. • Treat crypto like any other new product — build the risk stack first. Before launch, document product-level risk assessments covering market/price 28 NEBRASKA BANKER
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