INVITING QUESTIONS to Spark Better Conversations 2026 • Issue 1 Fraud Victim Support How Financial Institutions Can Respond and Restore Trust
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6 ©2026 Nebraska Independent Community Bankers (NICB) | Memberlink Solutions DBA The newsLINK Group LLC. All rights reserved. The Nebraska Independent Banker is published six times per year by The newsLINK Group LLC for NICB 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 NICB, 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. The Nebraska Independent Banker is a collective work, and as such, some articles are submitted by authors who are independent of NICB. 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. Nebraska Independent Community Bankers 1201 Lincoln Mall, Ste. 103 Lincoln, NE 68508 (402) 474-4662 nicbonline.com The Nebraska Independent Banker is a publication of The Nebraska Independent Community Bankers Association. 2026 • Issue 1 Take a Look INSIDE 12 16 NICB Executive Committee CHAIRMAN Jim Niemeier Citizens State Bank Friend PRESIDENT/CEO Dexter Schrodt SECRETARY Kelly Lenners First State Bank Nebraska Pickrell TREASURER Arnold Lowell CerescoBank Ceresco IMMEDIATE PAST CHAIRMAN Rick Heckenlively Points West Community Bank Sidney FLOURISH 4 Marching Into 2026 on the Advocacy Frontline By Rebeca Romero Rainey, President and CEO, ICBA PORTFOLIO MANAGEMENT 6 Lies and Statistics Community Bank Bond Portfolios Have Latent Strengths By Jim Reber, CPA, CFA, President and CEO, ICBA Securities 9 The Mental Toll of Money Stress and How to Support Your Account Holders By Fred Stapleton, VP of Relationship Management, CSI 12 Inviting Questions to Spark Better Conversations By Lindsay E. LaNore, Senior Executive Vice President, Chief Learning & Experience Officer, ICBA 14 Unlock Hidden Card Revenue with BINs By Jacob Eisen, CEO, ICBA Payments 16 Fraud Victim Support How Financial Institutions Can Respond and Restore Trust By Terri Luttrell, CAMS‑Audit, CFCS, Compliance and Engagement Director, Abrigo 20 FDIC Interest Rate Restrictions Rate Limits Under 12 CFR Part 337.7 By Debbie Walker, Director of Regulatory and Compliance, QwickRate 22 NICB Endorsed Partners 22 Associate Members 2026 23 Banker Showcase We Want to Feature You in Our Next Issue of The Nebraska Independent Banker! NEBRASKA INDEPENDENT BANKER 3
Looking back on 2025, we have advocacy successes to celebrate. From tax reform and the ACRE tax deduction for interest earned on agricultural real estate loans to President Donald Trump signing into law legislation to bar credit reporting agencies from selling “trigger leads” when consumers apply for a residential mortgage, we have seen developments that signal a deeper understanding of the role community banks play. We’ve also witnessed a rising awareness of the ways community banks differ from other financial institutions. Rule writing that promotes a more level playing field has begun to emerge, and reforms at the banking agencies and the Consumer Financial Protection Bureau are more accurately addressing the unique role community banks play in the financial services ecosystem. These and other wins mean our message is resonating in Washington and beyond. But we are far from done. FLOURISH MARCHING INTO 2026 ON THE ADVOCACY FRONTLINE By REBECA ROMERO RAINEY, President and CEO, ICBA 4 NEBRASKA INDEPENDENT BANKER
Let’s Dive Deeper These wins are only the tip of the iceberg; there’s a whole foundation of issues that we need to dive deeper into to address. That’s why we implore you to get involved in our advocacy efforts. When you speak up on behalf of community bankers, you truly make an impact. For instance, on trigger leads, I heard from a bank leader who said he had a residential lender in the bank who was appalled at what was happening. This lender became involved with ICBA, attended ICBA’s Capital Summit and met with her legislators to discuss the issue. As a result, she helped resolve the issue, in part because she took the time to speak up. Now she has shared with me that she’ll be a community bank advocate for life. In a world where everyone wants to call themselves a bank, we must ensure that legislators and regulators understand what makes community banks different. Pushing Into the Future We should take a moment to reflect with pride on our successes, but then we must move on to what’s next. We cannot and will not let up on the pressure we must exert on policymakers to ensure we have a level playing field to better support our communities. We must lean in further and harder to represent the industry. In a world where everyone wants to call themselves a bank, we must ensure that legislators and regulators understand what makes community banks different. We need you to engage and become even bigger advocates to ensure that all our communities have access to the financial services they deserve. We look forward to seeing you in the starting lineup in the weeks to come. On behalf of everyone at ICBA, I wish you a prosperous year. NEBRASKA INDEPENDENT BANKER 5
PORTFOLIO MANAGEMENT By JIM REBER, CPA, CFA President and CEO, ICBA Securities LIES AND STATISTICS I think most bankers, being numbers people by trade, have some familiarity with the phrase in this headline, which is often associated with Mark Twain. At times, it has been suggested that your correspondent, a certified public accountant, can take numbers and analyses to a different (and possibly lower) level than the average financial professional. For the next four minutes, I am going to attempt to weave some observations about the current posture of community bank bond portfolios into a cogent column. Spoiler alert: What follows is mostly positive commentary. As I have stated before, I hold portfolio managers in high regard. There are years of data that demonstrate how bankers can identify opportunities and, just as importantly, Community Bank Bond Portfolios Have Latent Strengths 6 NEBRASKA INDEPENDENT BANKER
looming risks, and then adjust on the fly. Which is not to say they collectively act compulsively — it’s clear that community bankers have a highly developed sense of risk/reward dynamics. Where We’ve Been The previous table displays some key bond portfolio statistics going back a decade. Our data comes from the bond accounting population of ICBA Securities’ endorsed broker-dealer, Stifel. For a refresher, let’s recall where the community banking industry stood in 2015. It’s a good point to pick up this conversation, as it signaled a new phase in the Fed’s monetary policy. The FOMC raised the target level of fed funds from 0.25% to 0.50% in December 2015, marking the first change since the onset of the Great Recession in 2008. The table reveals several residuals of that long stretch of low market yields. To wit: short durations, high levels of short-term principal cash flow and tax-equivalent yields that were not, shall we say, ambitious. Interestingly, yields didn’t really get any better until 2018, even though the Fed hiked overnight rates nine times in that three-year window. As low market rates endured for an extended period in the “teens,” average book prices consistently hovered in the 102 range. What’s Happening Now For the past three years or so, a different set of variables has emerged. The most durable (and cringe-inducing) metric is the unrealized loss. As of Sept. 30, the average portfolio had a loss of 7% or more. Since we’re finally embarking on a rate-cut cycle, those numbers should improve (shrink), though that’s largely dependent on how the long end of the yield curve reacts. Two positive and notable developments are the continued improvement in yields, which are now over 3% for the first time in at least a decade, and the normalization of the 24-month principal cash flows to the longer-term run rate of around 25% of the total bond portfolio. Effective durations are still longer than most community banks’ preferences but have declined since 2022, reflecting another positive trend. What Else We’ve Seen The “higher for longer” rate cycle has produced a couple of other benefits. The average portfolio’s book value is effectively par (100.00), which hasn’t been the case since before the Great Recession, around 18 years ago. This means that rate shocks, should they occur, won’t have a profound effect on book yields, since neither discount accretion nor premium amortization will be significant. From the same chapter: The collection of bonds on hand can actually appreciate several percentage points before hitting the premium compression wall. If a group of bonds is owned at, say, 102 cents on the dollar, a drop in market yields will pull up the prices far less than if they’re owned at 100 cents on the dollar. So, the desirable element of convexity could come into play this year. There is your update on the Xs and Os of well-built bond portfolios. It’s quite evident that ICBA members’ balance sheets are managed with care and thought. Portfolios are larger than they’ve ever been, but there’s no yield grab, and bankers have been patient with the unrealized losses, which continue to decline. I’d like to wend back to the estimable Mr. Twain for a closing thought: “Substitute ‘damn’ every time you’re inclined to write ‘very’; your editor will delete it, and the writing will be just as it should be.” Or not. Jim Reber, CPA, CFA (jreber@icbasecurities.com), is president and CEO of ICBA Securities, ICBA’s institutional, fixed-income broker-dealer for community banks. Thank you to ICBA affiliates for your 2025 support! ICBA Securities and its exclusive broker-dealer, Stifel, participated in education events for 29 ICBA state affiliates in 2025, marking the third consecutive year we’ve broken our own record for association event participation. We are grateful for the relationships we’ve made and look forward to more collaboration ahead. NEBRASKA INDEPENDENT BANKER 7
| Bank Stock Loans | Loan Participations | ATM/Debit | International Services | | Cash Management | Securities Safekeeping | Merchant Services | 800-873-4722 | NE: 888-467-5544 | www.bbwest.com Where community banks bank Est. 1980 – 45 years of service to community banks “As a service provider exclusively focused on community banks, Bankers’ Bank of the West is here to help strengthen our clients and the communities they serve.” Across the western states and Great Plains, we’re the place where community banks bank. That’s because we provide the services, technology, and expertise to help you extend your resources, deliver for your customers, and stand out in your market. 5 reasons to partner with us BBW - President and CEO - Bill Mitchell 1. You can unlock efficiencies and cost savings. We can provide sophisticated solutions and economies of scale because we’re powered by hundreds of community banks across our region. 5. Our priorities are aligned with yours. 2. You can expand your capabilities. 4. We’ll never compete for your customers. 3. You can count on prompt, reliable service. • Independent loan review • Loan and credit administration consultation • Strategic planning facilitation • Management, staffing, & succession planning • Acquisition & expansion • BSA/AML compliance • Regulatory risk consultation President, Jim Swanson President, Anne Benigsen • Consulting • Phishing Tests • Vulnerability Management • Security Monitoring Cyber/information security, strategic planning, independent loan review, AND MORE. Consulting Services $ 8.45B assets under management $ 1.9B daily transaction value processed/settled Serving more than 60% of community banks across 7 states
It’s been a turbulent few years, beginning with the pandemic and followed by persistent inflation, rising housing costs and uncertainty surrounding economic policy. In the U.S., 77% of adults experience financial anxiety, and 58% feel like money controls their lives. More than one-third of adults say financial problems have directly affected their mental health. Left unchecked, feeling financially squeezed can escalate into depression, anxiety or avoidance behaviors that make the problems worse. Long-term financial strain has also been associated with higher cortisol levels, fatigue and an increased risk of cardiovascular disease, along with other physical concerns. The link between personal finances and emotional well-being is undeniable. With that in mind, community financial institutions have an opportunity to offer responsible support that helps reduce financial stress and better serve the people who rely on them. With the right approach, they can help account holders ease anxiety and regain a sense of stability. How Financial Institutions Can Help When people are under financial pressure, they may lose confidence in their institution if they feel judged or overlooked. Empathy and proactive support serve both human and business needs, strengthening relationships and building long-term loyalty. Account holders who feel understood during difficult periods are more likely to stay and more willing to explore additional products and services later. THE MENTAL TOLL OF MONEY STRESS and How to Support Your Account Holders By FRED STAPLETON VP of Relationship Management, CSI NEBRASKA INDEPENDENT BANKER 9
Community banks and credit unions have a natural advantage over larger or online-only institutions because they are deeply integrated into the communities they serve. They are not distant or anonymous organizations; they are staffed by people who often know their account holders personally and genuinely want to help. That proximity and trust provide a foundation for easing financial stress in meaningful ways. Here are some ways to put that advantage to work. Proactive Financial Education A 2025 PYMNTS study found that 65% of U.S. adults live paycheck to paycheck, leaving little room for unexpected expenses. To address this stress, financial institutions can offer financial wellness workshops, budgeting tools, digital courses, and personalized guidance to help account holders manage debt, build savings and plan ahead. They can also expand this support by incorporating digital tools such as credit monitoring, score simulators, and financial management dashboards within online and mobile banking. These resources help account holders understand how day-to-day decisions affect their financial health in real time. One recent study found that 47% of users of a financial wellness platform reported lower financial stress, highlighting how education can replace anxiety with assurance. Fair and Responsible Liquidity Options When cash flow is tight, many consumers make short-term decisions that can cause long-term harm, such as turning to payday lenders, pawn shops or high-interest credit cards. One-third of those living paycheck to paycheck have skipped or partially paid a bill, risking late fees, loss of service or damaged credit. Community banks can offer a safer alternative by providing fair, transparent liquidity solutions. Services like overdraft protection and short-term, small-dollar loans provide access to much-needed funds without excessive fees or predatory terms. When these services use dynamic limits tied to an account holder’s ability to repay, they create helpful breathing room while reinforcing healthy financial habits and building trust over time. Personalized Communication and Engagement Money stress is deeply personal, and support should reflect that. Using data, analytics and segmentation, financial institutions can tailor their communication to specific behaviors and needs. They can send alerts for spending spikes, offer encouragement when savings grow or share tips when patterns suggest strain. These timely, relevant touchpoints reassure account holders that their institution is paying attention and stands ready to help. A 2025 FICO survey found that 88% of consumers consider experience just as important as a financial institution’s products and services. Personalized engagement can improve the customer experience and solidify the financial institution as a trusted partner. Normalizing Conversations About Money Stress Despite being a leading source of stress for many, money remains one of the most difficult topics to discuss. Only a little more than half of adults say they feel comfortable discussing it, and nearly half feel embarrassed sharing details about their financial situation. Community financial institutions can play a role in shifting this mindset. By acknowledging financial stress openly and without judgment through blogs, newsletters, social media, events or webinars, they make the topic easier to approach. Honest, empathetic communication builds trust and encourages people to seek help before problems escalate. 10 NEBRASKA INDEPENDENT BANKER
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 Building Account Holder Trust With Empathy Consumers today want more than low fees when choosing a bank or credit union. They want a partner they can trust, especially when stress is high. Financial health is closely tied to emotional health, and institutions that recognize this connection and lead with empathy stand out as true allies in their account holders’ lives. By pairing empathy with education, technology, meaningful services, and personalized support, community institutions can honor their commitment to the people they serve, help alleviate the emotional weight of financial stress and strengthen the relationships that matter most. Scan the QR code to access CSI’s on-demand webinar exploring how community financial institutions can strengthen customer relationships and make a measurable difference. https://www.csiweb.com/what-to-know/content-hub/ odwebinars/unlocking-financial-wellness-tools-andstrategies-for-community-banks/ Financial health is closely tied to emotional health, and institutions that recognize this connection and lead with empathy stand out as true allies in their account holders’ lives. NEBRASKA INDEPENDENT BANKER 11
Inviting Questions TO SPARK BETTER CONVERSATIONS
We all know how powerful curiosity can be. Every great leader knows that inviting feedback and questions from their team can be a highly collaborative and productive process. However, the ways we solicit questions can vary — as can the results. To get the results you want, consider making subtle adjustments to the way you invite questions and solicit feedback from your team in meetings or other contexts. Let’s look at three different methods, starting with the classic: “Does anyone have any questions?” When it comes to a conversation starter, it’s polite, simple and familiar. But it’s often met with silence. As a question, it leaves ambiguity in the air, implying that questions are optional or worse, not even wanted. It can signal that you, as a leader, are ready to move on. There’s also a great deal of social pressure attached to it. Participants may hesitate to reply, thinking their question isn’t “good enough,” or they may want others to break the ice and speak first. As a result, this approach generally yields low engagement, and questions often remain unasked. Let’s try a more interactive approach: “What questions do you have?” The most important quality of this prompt is that it assumes there are existing questions. It implies that curiosity is normal and encouraged. It invites participation and signals openness, with an expectation of dialogue. And yet, it may still be too broad, leaving some team members unsure where to begin. It may also feel performative if it isn’t backed by genuine interest. That said, it lowers the threshold for speaking up, solicits more thoughtful responses and encourages moderate engagement. The Two-Question Method The third approach isn’t a question at all, but rather an invitation to participate: “Ask me two questions.” Asking everyone in the room to formulate two questions makes participation a shared responsibility and creates a psychologically safe space by making asking questions the norm. It may feel a little forced, especially if trust hasn’t already been built. Your team may also feel unprepared or put on the spot. However, normalizing this kind of dialogue in meetings means that while they may be caught off guard the first time, they certainly won’t be the second or third time it happens. This invitation encourages high engagement and, when used with care, signals that questions are valued, fostering more meaningful conversations. In today’s fast-paced and stressful work environments, we need all the advantages we can get. It’s important to recognize that even the smallest adjustments can make a big difference. So, go ahead: ask me two questions! By LINDSAY E. LaNORE Senior Executive Vice President, Chief Learning & Experience Officer, ICBA NEBRASKA INDEPENDENT BANKER 13
When it comes to card revenue, having the right bank identification number (BIN) type is critical. BINs are the first six to eight digits on a card that identify the issuing institution and card type, but their impact extends beyond labeling a transaction. BINs are assigned differently for commercial or consumer accounts, reward- or non-reward-based transactions, and debit or credit payments. The right mix can make the difference between a highly profitable card program and the status quo. Different BIN types trigger different interchange levels — the percentage a bank can earn on each transaction — so they can drastically affect a card program’s returns. For instance, a $10 million portfolio using an incorrect BIN structure could lose five to 10 basis points of interchange — tens of thousands annually in unrealized revenue. For this reason, every community bank with a card program should take time to assess its BIN status, ensure it aligns with the ways the card is being used, look for ways to maximize revenue and seek to optimize its program. Specifically, community banks should consider the following steps: 1. Incorporate business BINs into portfolios. ICBA Payments works with clients to optimize their card programs and often uncovers consumer BINs being used by small businesses. Using a consumer BIN for a business transaction equals lost revenue: Business BINs pay 90 to 100 basis points more than consumer cards. By simply deploying the right BIN for the type of transaction, community banks stand to earn more. By JACOB EISEN CEO, ICBA Payments UNLOCK HIDDEN CARD REVENUE with BINs 14 NEBRASKA INDEPENDENT BANKER
2. Limit the number of PIN-based point-of-sale (POS) networks in portfolios. There are network participation fees for these networks, so by limiting the portfolio to one PIN POS, community banks can lower their costs and support better revenue margins. 3. Develop campaigns targeting higher interchange transactions and encouraging card use. Travel and dining drive higher interchange rates, so consider campaigns that encourage card use in these segments. Little shifts add up to a lot: If a bank with 10,000 cards can drive one more transaction per month across their card base, it will earn $65,000 more in interchange per year. Community banks can increase interchange revenue through simple strategic shifts because, at its core, interchange optimization is about accuracy. Banks that confirm their BIN classifications, analyze interchange by product type and ask for transparency on how transactions are routed will see stronger returns on their card programs. Next Steps To optimize your BINs, reach out to your ICBA Payments relationship manager or email payments@icba.org. Jacob Eisen (jacob.eisen@icba.org) is CEO of ICBA Payments and its wholly owned subsidiary TCM Bank. Community banks can increase interchange revenue through simple strategic shifts because, at its core, interchange optimization is about accuracy. NEBRASKA INDEPENDENT BANKER 15
Fraud Victim Support How Financial Institutions Can Respond and Restore Trust By TERRI LUTTRELL, CAMS‑Audit, CFCS Compliance and Engagement Director, Abrigo As fraud schemes evolve in complexity and scope, financial institutions are called upon to do more than just detect and prevent illicit activity. Banks and credit unions often also serve as first responders when individuals or businesses fall victim to financial fraud. Institutions that respond with urgency and empathy to support victims of fraud can rebuild trust, restore confidence and reinforce long-term relationships with clients. But fraud victim support is about more than recouping financial loss. Understanding the common fraud schemes clients may encounter and taking an intentional approach to assist in the aftermath demonstrates an institution’s values, dedication to client care and role as a trusted advisor within the community. The Growing Cost of Fraud Reported fraud losses exceeded $12.5 billion in 2024, according to the Federal Trade Commission (FTC). The FBI documented an even higher total loss of over $16.6 billion across 859,000 complaints. These figures speak not only to the scale of financial harm but to the emotional toll these crimes leave behind. The volume and impact of fraud are increasing across all channels. In 2024, investment scams topped the list in financial damage, with $5.7 billion in reported losses. Imposter scams followed closely at nearly $3 billion. Criminals prey on trusting and vulnerable people, and they continue to leverage digital platforms to initiate contact via email, phone or text, and move funds through cryptocurrency, bank transfers or wire services. According to the FBI, phishing scams were the most frequently reported. However, business email compromise and investment fraud caused the most significant monetary damage. These trends highlight the urgent need for comprehensive fraud victim support programs that go beyond the basics of account recovery. Understanding the Scope of Fraud Financial institutions must first understand the various forms of fraud affecting their clients to deliver meaningful assistance. Some of the most prevalent methods include: • Cybercrime Attacks: Cybercrime attacks occur approximately every 11 seconds, costing organizations an average of $13 million per incident. Small businesses are especially vulnerable due to limited cybersecurity infrastructure. 16 NEBRASKA INDEPENDENT BANKER
• Consumer Fraud: Consumer fraud takes many forms, including synthetic identity theft, spoofing, romance scams and grandparent scams. These often target the elderly and financially inexperienced. • Business and Investment Fraud Schemes: Scams such as Ponzi operations, business email compromise and wire fraud continue to result in insignificant losses for commercial clients. • “Pig Butchering”: A particularly alarming emerging scam is known among criminals as “pig butchering” because victims are deceived over time through emotional manipulation before being persuaded to make large financial transfers. Each scheme can leave a trail of emotional distress and financial disruption. A thoughtful, informed approach to fraud victim support is essential to help affected individuals navigate the aftermath. A Layered Approach to Fraud Victim Support 1. Prevention Through Education and Technology Preventing fraud begins with awareness. Banks and credit unions can help clients identify red flags by offering regular educational materials across digital and in-person channels. Topics include the creation of secure passwords, the identification of phishing attempts and safe usage of peer-to-peer payment apps. Technology also plays a pivotal role in prevention. Sophisticated fraud detection tools incorporating artificial intelligence and behavioral analytics can monitor suspicious activity in real-time. Institutions can also empower their clients with biometric login, multi-factor authentication and real-time fraud alerts. 2. Helping Clients Create a Response Plan Helping clients prepare a response plan before fraud occurs can reduce confusion and stress if the worst happens. Encourage clients to keep a written checklist that includes how to report fraud to their financial institutions, contact information for the FTC and FBI, and steps for freezing credit with the major bureaus. The plan should also cover resetting login credentials and enabling fraud alerts. Reviewing this plan regularly gives clients confidence that they know what to do and who to call. It is a simple way to support a long-term client relationship. 3. Responding With Clarity and Compassion A fast and empathetic response is critical following a fraud incident. Banks and credit unions should have clear procedures in place to support victim response plans, including measures around: • Freezing or closing affected accounts • Reissuing account credentials and payment cards • Assisting with dispute processes and documentation • Communicating directly with law enforcement when appropriate Empowering front-line employees to handle these cases with care can help ease client anxiety and reestablish trust during a particularly vulnerable time. 4. Supporting Financial Recovery While banks and credit unions often must reimburse clients for unauthorized transactions, many fraud cases involve victims being tricked into authorizing payments. In these situations, reimbursement is not always guaranteed. Still, financial institutions can support victims with the following meaningful actions: • Assist With Regulatory Reporting: Help victims file official complaints with the FTC, the FBI or the Consumer Financial Protection Bureau (CFPB). These reports establish a record of the incident and contribute to broader fraud tracking efforts. • Work With Law Enforcement and Other Financial Institutions: Cooperate with authorities and peer institutions to trace stolen funds and flag suspicious accounts. Swift action can help contain damage and may lead to partial recovery. • Provide Recovery Resources: Refer victims to identity theft protection services, legal aid or nonprofit support organizations. These resources can help clients manage credit impacts and protect against future fraud. Even when full financial recovery is impossible, these steps demonstrate a commitment to care and accountability. Institutions prioritizing fraud victim support during recovery reinforce trust and deepen client relationships. NEBRASKA INDEPENDENT BANKER 17
5. Sustaining Support Beyond the Incident Helping a client through the immediate fallout of fraud is the first step. Ongoing protection is key to rebuilding confidence. Financial institutions can offer continued support through: • Identity theft monitoring • Credit and account activity alerts • Help with placing credit freezes • Referrals to advocacy groups for seniors or other vulnerable individuals Staying engaged after the crisis helps banks and credit unions show they are not just financial service providers but also long-term partners in their clients’ security and peace of mind. Making Victim Support a Shared Responsibility An effective response to fraud must involve collaboration across internal teams. Anti-money laundering (AML), information technology, fraud prevention and client service departments should operate under a unified plan to ensure quick and coordinated action. Regular training and updates on emerging fraud trends are essential. Equally important is leadership support. Institutions that invest in fraud prevention tools, adequate staffing and client education signal that fraud victim support is not a side function but a core priority. Turning Crisis into Opportunity Fraud response efforts should be viewed as risk mitigation and opportunities to lead with purpose. Financial institutions can demonstrate their commitment to ethical banking and social responsibility by standing with victims and guiding them through recovery. Banks and credit unions that take fraud victim support seriously will be better positioned to retain loyal clients, enhance their brand reputation and serve as trusted pillars in their communities. Terri Luttrell is a seasoned AML professional and former director and AML/OFAC officer with over 20 years in the banking industry, working both in medium and large community and commercial banks ranging from $2 billion to $330 billion in asset size. 100 South Phillips Avenue, Sioux Falls | (605) 335-5112 | advantage-network.com WE UNDERSTAND COMMUNITY BANKS Born from a community bank to serve financial institutions,The Advantage Network has a unique understanding of your needs. With debit card services, card production, marketing support, ATM services, and fraud monitoring, our goal is to help you increase non-interest income — while providing the high-touch, personalized customer service our team is known for. Reach out, and let’s start a conversation! 18 NEBRASKA INDEPENDENT BANKER
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FDIC Interest Rate Restrictions Rate Limits Under 12 CFR Part 337.7 By DEBBIE WALKER Director of Regulatory and Compliance, QwickRate FDIC regulations impose deposit interest rate restrictions on insured financial institutions that are less than well capitalized. Such restrictions have been in place since 1992 and were designed to prevent a less than well capitalized institution from offering deposit rates that significantly exceed the prevailing rates in its normal market area. On Dec. 15, 2020, the FDIC issued a final rule that amends its methodology for calculating interest rate limits. As of April 1, 2021, the agency uses different approaches to determine the National Rate, the National Rate Cap and the Local Market Rate Cap, which the FDIC uses to ensure that an institution offers interest rates appropriate for its capitalization status. 20 NEBRASKA INDEPENDENT BANKER
National Rate Historically, the National Rate was calculated as a simple average of rates paid by all depository institutions and branches that offer and publish rates for specific products. Under the new regulation, the FDIC defines the National Rate as the weighted average of rates paid by all IDIs and credit unions on a given deposit product (for which data are available), based on each institution’s market share of domestic deposits, not its number of branches, as was previously the case. National Rate Cap A less than well capitalized bank may not offer a deposit rate higher than the National Rate Cap for deposits of similar size and maturity. In its new regulation, the FDIC offers two options for determining the National Rate Cap. These options were configured to ensure that less than well capitalized institutions can compete for deposits in both high-rate and rising-rate environments, as well as in low-rate or falling-rate environments. As of April 1, 2021, the National Rate Cap is defined as the higher of: • the National Rate plus 75 basis points; or • 120% of the current yield on similar maturity U.S. Treasury obligations plus 75 basis points or, in the case of any non-maturity deposits, the fed funds rate plus 75 basis points. Local Market Rate Cap When generating deposits in its local market, a less than well capitalized bank may establish its interest rate offer using the Local Market Rate Cap, which is now equal to 90% of the highest rate offered on a particular deposit product by an insured depository institution or credit union in the institution’s geographic local market area. An institution utilizing the Local Market Rate Cap will be required to notify its FDIC regional director that it intends to offer a rate that exceeds the National Rate Cap. This notification must be supported by evidence that another financial institution in its local market area is offering a rate on a particular deposit product in excess of the National Rate Cap. The specified local market may include the state, county or metropolitan statistical area in which the insured depository institution accepts or solicits deposits. Rates for Odd Terms Standard maturity terms include: one month, three months, six months, 12 months, 24 months, 36 months, 48 months and 60 months. All other term periods are considered “off tenor” for the purpose of this regulation. If a bank offers a deposit with an off-tenor maturity for which the FDIC does not publish a National Rate Cap, and if the off-tenor maturity term is not being offered by another institution within the bank’s local market area, the bank must use the rate provided in the next lower standard maturity term for that product when determining its applicable national or local rate cap. For example, an institution seeking to offer a 26-month certificate of deposit must use the rate provided for a 24-month certificate of deposit to determine the institution’s applicable national or local rate cap. The FDIC publishes the National Rate Cap information on its website, along with monthly updates, which can be accessed by scanning the QR code. (The FDIC maintains the discretion to publish updates more or less frequently, if needed.) https://www.fdic.gov/national-rates-andrate-caps For more information, contact Debbie Walker, Director of Regulatory and Compliance at QwickRate, at (678) 797-4056, or call customer service at (800) 285-8626. QwickRate® provides the premier non-brokered CD marketplace for funding and investing, with fast connections to more than 3,000 institutions to proactively manage liquidity needs. QwickRate offers other affordable tools and services to help simplify and make work easier for bankers. The IntelliCredit loan review and credit intelligence solutions provide banks with a more efficient way to detect and manage risk, enabling them to move a decades-old loan review process online. QwickAnalytics provides time-saving bank research, performance analysis and regulatory tools, including CECLSolver and Credit Stress Test. NEBRASKA INDEPENDENT BANKER 21
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