2026 ISSUE 3 Leadership Division at the Capitol April 15
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INSIDE THIS ISSUE PO Box 1765 Jefferson City, MO 65102 (573) 636-2751 | miba.net Editor: MATTHEW S. RUGE Executive Director ©2026 The Missouri Independent Bankers Association (MIBA) | MBR Connect™, formerly The newsLINK Group LLC. All rights reserved. The Show-Me 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 MIBA, 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 Show-Me Banker is a collective work, and as such, some articles are submitted by authors who are independent of MIBA. 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. Published for the Missouri Independent Bankers Association 4 PRESIDENT’S MESSAGE Staying Competitive While Staying Local 6 FROM THE TOP Turning Fraud on Its Head 7 FLOURISH Battling Check Fraud Together 8 2026 Directors and Officers Seminar April 28-29 10 49th Annual MIBA Convention & Expo The Best Place to Connect With Missouri Community Bankers 11 BACKGROUND ON Kyle Scherder Vice President, Community State Bank of Missouri 14 MEET YOUR MISSOURI BANKER Doreen Scarborough Vice President, Compliance & Audit, Pony Express Bank 16 Leadership Division at the Capitol April 15 18 LEGAL EAGLE SPOTLIGHT SBA, DOJ Intensify PPP Enforcement Key Risks for Borrowers and Lenders 20 MIBA Lobbying Report 21 Upcoming Events 2026 22 PORTFOLIO MANAGEMENT In With the New Introducing The Baker Group, ICBA Securities’ New Endorsed Broker-Dealer 24 News From You 27 2026 PAC Honor Roll 28 Welcome New Associate Members 29 49th Annual Golf Tournament Monday, Sept. 14, 2026 30 2026 Scholarship Winners 31 FDIC Directors’ College April 21 32 Continuous IT Compliance Turning Audit Risk Into Capital Strategy 33 36th Annual Scholarship Auction Browse and Bid for a Great Cause! 34 2026 MIBA Financial Directories Are Available 35 MIBA’s Endorsed Vendors Are Ready to Help You Go Further 36 MIBA Associate Members 38 Upcoming Webinar Schedule 40 MIBA's 49th Annual Convention & Expo September 14-16, 2026 14 30 8 6 The Show-Me Banker Magazine | 3
PRESIDENT’S MESSAGE Staying Competitive While Staying Local For community banks, success has always been rooted in relationships, trust and local presence. While those fundamentals remain unchanged, the way banks reach, serve and grow their customer base continues to evolve. Marketing and business development now play a more prominent role in supporting them, helping banks remain competitive while staying true to their community-focused mission. Approaches to marketing and business development can vary greatly. While these two functions are distinct, they should work together to support and complement the bank’s overall goals. Marketing primarily focuses on retaining and attracting customers. In contrast, business development is centered on driving growth, identifying opportunities and building relationships within the market. In general, marketing is about increasing visibility — often called “top-of-mind awareness” — and driving revenue growth, while business development focuses on expanding the bank’s reach and long-term growth opportunities. Together, these strategies should align to drive growth, profitability and the bank’s strategic vision, both in the short and long term. The structure of marketing and business development efforts can differ significantly Curt Brumley MIBA President, Community Point Bank by bank, depending on size, needs and market perception. Marketing functions may be handled in-house or outsourced to a marketing firm, while business development is typically driven by the bank’s leadership and goals. Advancements in technology, shifts in customer behavior and varying levels of technology adoption across generations 4 | The Show-Me Banker Magazine
have greatly increased the importance of marketing. Banking has evolved from the days of being “the only bank in town” on the city square to operating in a highly competitive and digital environment. Marketing was once viewed primarily as an expense, but changes in customer behavior and technology have reshaped it into a key driver of growth. Marketing continues to evolve with the times. Establishing a strong brand is essential to differentiate your bank. Digital marketing has expanded significantly, providing opportunities to reach broader audiences and guide potential customers to your website. Emerging tools such as artificial intelligence allow banks to further refine and target their marketing efforts. These technological changes have solidified marketing’s role as a strategic investment rather than simply a cost. One of the challenges we face at our bank is effectively utilizing various marketing channels to reach the multiple generations we serve. To meet the needs and preferences of each group, we employ a diverse mix of methods, including digital platforms, streaming services, social media and traditional television. Showing up and being actively engaged in the community remains one of the most effective marketing tools for any bank. We actively support local events, schools and churches; engage with students; volunteer; provide financial education; and participate in community activities such as livestock sales. These efforts reflect our commitment to the community and help foster meaningful relationships. When people feel positively about your organization, they are more likely to engage in word-of-mouth referrals — one of the most impactful forms of business development. These referrals are powerful because they represent a genuine endorsement from one customer to another. At our bank, this is driven by a focus on exceptional service and expertise, which allows customer referrals to flow naturally and play a significant role in growth. The importance of aligning marketing and business development has grown significantly in today’s competitive and technology-driven environment. However, the question is no longer whether these functions matter — it is how intentionally and effectively they are being used within your organization. As bankers, we should be asking ourselves: Are our marketing efforts truly aligned with our growth goals? Are we leveraging the right mix of channels to reach our customers where they are? Are we empowering our teams to actively participate in business development and relationship building? Are we consistently delivering a level and quality of service that naturally drives word-of-mouth referrals? There is no one-size-fits-all approach. Take time to evaluate your current strategies, identify gaps and consider where a more coordinated effort between marketing and business development could accelerate your bank’s growth. In a rapidly changing landscape, banks that combine strong strategy with genuine relationships will not only compete — they will continue to strengthen the communities they serve. End-to-End Security, Missouri-Ready Compliance. Get end-to-end security plus hands-on exam support designed for Missouri community banks. Gain access to JMARK's award-winning security platform FORTIFY and clean compatability with core environments. Clients report 11% fewer remediation tasks on average and 19.72% average asset growth over two years.* All managed by JMARK—so you can get back to banking. COMPREHENSIVE IT SOLUTIONS See how MO banks cut remediation with JMARK: JMARK.com/banking 844-44-JMARK JMARK.com *Figures represent client-reported outcomes across JMARK banking clients (2023-2025), on average. Results vary. The Show-Me Banker Magazine | 5
When it comes to fraud, what I worry about most is what we don’t know. Each day, there’s a new method of attack, and we must train ourselves and our teams to not only watch for it but to proactively combat it. Earlier this year, in a monthly all-hands-on-deck team meeting at Potomac Bank, we shared with every employee how much fraud cost us last year, how many attempts there were and how many reports about suspicious activity we filed. In addition, we dove into incidents in which we prevented a loss and how we did it, emphasizing what worked. As we all know, when there are fraud losses, something didn’t go to plan. Fortunately, that becomes a learning opportunity. “Sometimes you win — sometimes you learn,” wrote John C. Maxwell in his book of the same name. Every time my bank experiences fraud, we do an extensive review after the fact, asking the tough questions. Then, we explore ways we can catch and prevent that scam moving forward. Is there new technology we need? Should we evolve our procedures? How can we prepare better? It’s about turning that fraud experience on its head and utilizing information to enhance safety and security protocols. In conducting these fraud evaluations, we’ve also realized the power of communicating what we know. Because if we know about it, we can act against it. For example, in the fourth quarter of 2025, Potomac Bank experienced treasury check fraud. When it occurred, I was able to reach out to my peers at other local community banks, share what happened, offer photos of the perpetrators and provide the details that could help them enhance their own procedures. But we went one step further and worked together to partner with the FBI, ultimately resulting in the capture of the individuals responsible. It was information sharing at its best. In addition, resources like ICBA Community help us connect with bankers throughout the U.S. A couple of years ago, a fraudulent check came through on a customer’s account, and we needed to connect with other banks. I suggested we try ICBA Community as a resource and requested contacts at three large banks. Within minutes, we had them and were able to reach out and resolve the issue. That’s the power of this community of community bankers. When it comes to fraud, “Sometimes you win — sometimes you learn.” If you have an opportunity to learn, share your experience. It can be embarrassing to admit your processes failed and your bank experienced a loss, but the benefits to the larger group of community bankers far outweigh the discomfort. The more we work together and share, the more we know and the better positioned we all will be to combat what emerges next. FROM THE TOP Turning Fraud on Its Head Alice Frazier, Chair, ICBA Quote of the Month “Sometimes you win — sometimes you learn.” — John C. Maxwell 6 | The Show-Me Banker Magazine
FLOURISH Rebeca Romero Rainey President and CEO, ICBA guides and online courses to help community banks better prepare for emerging fraud scenarios. We also have delivered a way to connect with technology providers via our Solutions Directory, which aggregates community bank-supportive service providers that can help to address fraud. In addition, to aid customer awareness and education, we developed a customizable news release and check fraud prevention flyer that can be shared within your communities. Perhaps one of the most powerful tools at our disposal, ICBA Community has a members-only fraud subgroup, which allows this community of community bankers to share information on the latest scams and offer heads-up alerts on emerging threats. This important information sharing helps community banks be on the lookout for fraud that might affect them. Fraud is ever-present, and locking arms as a community will empower us to address all that is coming this way today and all that is on the horizon for tomorrow. While we can always count on new threats, together with the right knowledge and tools, we can mitigate and lessen losses, supporting a safer, more secure environment for our customers and the communities we serve. It’s becoming a frequent and unfortunate occurrence to hear community bankers recounting stories of fraud, and the attacks range from sophisticated digital scams to paper-based fraud rings. On one hand, we’re dealing with AI-induced deep fakes and advanced phishing scams. On the other, we’re having a real “Back to the Future” moment as old-school check washing makes a comeback, supported by digital image-altering technology that makes it simpler than ever before. But with all we’re fighting, check fraud remains one of the largest single contributors to our fraud problem. Industry data puts check fraud losses over the course of a year at $21 billion, and organized crime continues to ratchet up the intensity of the attacks. Despite these constant issues, checks remain a payment instrument of choice for our customers. In fact, the latest survey from the Association for Financial Professionals (AFP) found that while 63% of businesses experienced attempted or actual check fraud in 2024, 91% reported using checks, and more than 75% said they had no immediate plans to stop using them. Thus, we still see a steady volume of checks flowing through our organizations, a rate that our customers demand. To continue offering checks safely, we all must seek out advanced risk mitigation efforts. Fortunately, that’s where ICBA can help. For one, we offer our Check Fraud Resource Center, which provides Check Fraud Together Battling The Show-Me Banker Magazine | 7
April 28-29 Lodge of Four Seasons Lake Ozark, MO 2026 Directors and Officers Seminar 8 | The Show-Me Banker Magazine
Thank You, Sponsors The Show-Me Banker Magazine | 9
49th Annual MIBA Convention & Expo The Best Place to Connect With Missouri Community Bankers SEPTEMBER 14-16, 2026 Register now at miba.net! Position your company in front of Missouri’s top banking leaders at the 49th Annual MIBA Convention & Expo. Connect directly with CEOs and key decision-makers at a higher rate than many other industry trade shows! MIBA Member Exhibitors receive one complimentary registration for the full convention. Ready to reserve your space? The complete exhibitor prospectus — including booth details and the application — is available online. Visit miba.net and click the Annual Convention link to download. The exhibit hall always fills up, so get your booth request in ASAP! MIBA Associate Members Exhibitor registration for the MIBA Convention & Expo is now open for both members and non-member vendors. Booth spaces are going fast! Submit your request as soon as possible to secure your spot. Direct all exhibits questions to Jessica Rogers, Exhibits Coordinator, at (573) 636-2751 or jrogers@miba.net.
BACKGROUND ON Kyle Scherder Vice President, Community State Bank of Missouri For Kyle Scherder, community banking is more than a career — it’s a way to serve the place that shaped him. Born and raised in Bowling Green, Missouri, Scherder never imagined he would one day return home to build both his professional and family life in the same small town where he grew up. Today, as vice president of Community State Bank of Missouri, he can’t imagine being anywhere else. His story is grounded in relationships, hard work and a deep appreciation for community values. Though his path to banking wasn’t exactly what he first envisioned, it ultimately proved to be the perfect fit. “I really enjoy getting to work with people,” Scherder said. “In a small community, you know your customers. You’re helping them make some of the most important financial decisions of their lives.” That personal connection is what continues to drive him more than a decade into his career at Community State Bank. Scherder’s roots in Bowling Green run deep. Now, he and his wife, Olivia, are raising their own family there, balancing busy careers and an active household with their three children — Sally, Hattie and Gregory — and their dog, Lucy. Olivia works as a nurse at Hannibal Regional Hospital, and together they’ve embraced The Show-Me Banker Magazine | 11
the rhythms of small-town life that shaped Scherder’s upbringing. An Unexpected Path to Banking Like many who grow up in close-knit communities, Scherder once thought his future lay elsewhere. After graduating from Bowling Green High School, he attended the University of Missouri-Columbia and earned a bachelor’s degree in business administration with an emphasis in finance. At the time, though, his plan was to follow in his family’s footsteps. “My entire life, I wanted to go to Mizzou and become a tax accountant like my mother,” Scherder explained. “My grandfather owned his own practice in Bowling Green, and a lot of my family went through the Mizzou School of Accountancy.” When he wasn’t admitted into the accounting program, however, his path shifted — unexpectedly, but ultimately for the better. While in college, Scherder had taken a part-time job as a teller at Landmark Bank. What started as a practical way to earn extra income quickly grew into something more meaningful. “Looking back, I don’t know if I would have been a very good tax accountant,” he said with a laugh. “I really enjoyed being on the front line of the bank and talking to people.” Although banking became his long-term direction, Scherder’s accounting background still proved valuable. After college, he spent three and a half years as an auditor with Williams-Keepers LLC, a regional public accounting firm in Columbia, before returning to Landmark Bank in an internal audit role. Not long after, an opportunity emerged at Community State Bank of Missouri — just as he and Olivia were preparing for marriage and thinking seriously about the future they wanted to build. “At that stage of my life, I didn’t know if I wanted to be back in small-town Missouri,” Scherder admitted. “But now, raising a family here, I wouldn’t want it any other way.” More than 10 years later, he remains confident it was the right decision. Wearing Many Hats In his role as vice president, Scherder embodies the versatility required in community banking. He spends much of his time in lending, working with customers on home, agricultural and commercial loans, while also leading the bank’s Asset Liability Committee (ALCO), overseeing balance sheet management and managing the institution’s securities portfolio. “We’re a small community bank, so I wear several hats,” he said. “Every day is different. You really don’t know what your day is going to look like, and I enjoy that.” That variety is one of the aspects he values most, allowing him to combine analytical expertise with the relationship-focused side of banking. It’s also helped him grow into a leadership role while staying closely connected to both customers and colleagues. For Scherder, community involvement is simply part of being a community banker. He serves on the Bowling Green R-1 School District Education Foundation and is treasurer of the local Chamber of Commerce. He and his family are also active in their church, and Community State Bank regularly supports many local charitable organizations and foundations. Still, some of his most meaningful community involvement happens in a more personal setting — on the softball field and on the basketball court. A lifelong sports fan and devoted Mizzou Tigers supporter, Scherder spends his free time coaching youth softball and basketball, currently leading both a 10U and 8U softball team for his daughters. “I was fortunate that my parents were involved when I was growing up,” he said. “I think it’s important to be involved in stuff like that.” Though coaching leaves less time for hobbies like golf, he considers the trade-off well worth it. 12 | The Show-Me Banker Magazine
Lessons Learned Throughout his career, Scherder has also been shaped by mentorship, particularly from Community State Bank CEO Paul Hill and former co-CEO Mark Gooden. From Gooden, he learned the importance of listening — a skill that doesn’t always come naturally to someone who thrives on interaction. “He always emphasized taking time to listen — whether it’s a customer, coworker or someone who works under you,” Scherder said. “Hear what they’re saying process it and then respond.” From Hill, he gained a deeper appreciation for the power of relationships. “He’s always emphasized creating strong relationships with customers, coworkers and peers within the industry,” he said. “When people trust you, you’re able to help them on a deeper level.” These lessons now define Scherder’s own leadership approach, one grounded in connection, attentiveness and trust. When asked what advice he would give to someone considering a career in banking, Scherder’s answer comes quickly: build relationships, set goals and maintain a positive attitude. “Networking and building strong relationships are foundational,” he said. “That applies no matter what industry you’re in.” He also encourages young professionals to remain open to opportunities and work hard when those opportunities arise. “I think a lot of success comes from being goal-oriented and not passing up opportunities,” he said. Above all, attitude matters. “You can teach people how to be a banker,” Scherder said. “But attitude is huge.” He laughs that coworkers sometimes tease him for being overly optimistic, but he believes that positivity plays a critical role in both individual success and workplace culture. Looking Ahead Like many in the industry, Scherder is also keenly aware of the challenges facing community banks. Regulatory burdens remain a concern, particularly when rules designed for large institutions are applied broadly to smaller ones. “There’s often a broad brush applied to community banks,” he said. “The implementation doesn’t always fit institutions of our size.” Attracting and retaining talented employees — especially in rural areas — is another ongoing challenge, as is staying ahead of cybersecurity risks and increasingly sophisticated fraud schemes. Banks are investing heavily in technology and tools to protect customers, but education remains just as important. “Customers want to know their information and finances are safe,” Scherder said. “We also want them to understand how we communicate so they can recognize when something isn’t right.” Community State Bank of Missouri has long been involved with the Missouri Independent Bankers Association (MIBA), including through CEO Paul Hill’s service as a past president. Scherder himself has become increasingly active with the association over the past several years and currently serves on the board of directors. The association’s advocacy, education and networking opportunities are vital resources for community banks navigating an increasingly complex landscape. “There’s a lot to keep up with in banking,” he said. “MIBA helps keep us current on what’s happening across the industry.” He also appreciates the opportunity to connect with peers. “You can bounce ideas off others, ask questions and learn how they’re handling challenges. That camaraderie is really valuable.” For Scherder, banking always comes back to people — customers, coworkers, mentors and neighbors. And in Bowling Green, that sense of connection continues to affirm what he’s come to know over the years: Community banking isn’t just where he works. It’s where he belongs. The Show-Me Banker Magazine | 13
MEET YOUR MISSOURI BANKER Doreen Scarborough Vice President, Compliance & Audit, Pony Express Bank Where are your main bank and branches located? What is the market like? Pony Express Bank is headquartered in Braymer, with one branch in Liberty serving six counties, which include Caldwell, Clay, Clinton, Jackson, Platte and Ray counties. Braymer is a small community that focuses on supporting small business growth and agriculture. Liberty is experiencing significant growth with over $650 million in active projects, including major industrial expansion, downtown revitalization and new residential neighborhoods. Key developments include a massive $1.4 billion data center, new residential communities and infrastructure improvements along South Liberty Parkway. What is something unique about your bank? Something unique about our bank is that Pony Express Bank is a five-generation, family-owned institution led by the Page family. With a 133-year history, we combine deep-rooted tradition with personalized service. Despite having just over 40 employees, our team brings more than 800 years of combined banking experience, allowing us to deliver knowledgeable, relationship-focused service to our customers. How did you get started in the banking business? I began my banking career 44 years ago as a teller and, over time, gained experience across many areas of the bank. Along the way, I discovered a strong interest in compliance and regulatory matters. After earning my Certified Regulatory Compliance Manager (CRCM) certification, I went on to purchase a small consulting firm specializing in compliance, regulatory issues and internal control audits. For five years, I traveled extensively throughout Missouri and parts of Kansas, serving a variety of banks. During that time, one of my clients approached me about joining their organization, as their compliance officer was preparing to retire. That opportunity ultimately led me to my current role at Pony Express Bank. What is the most important thing you have learned from this career so far? People are understandably protective of their finances, and even small issues can cause significant concern. I found it genuinely rewarding to help resolve those problems, not only because it provided solutions but also because it built trust with customers. Over time, and especially after attending several leadership conferences, I discovered a passion for mentoring and teaching regulations to employees, which also built trust. That realization is a big part of why I continue to enjoy my work every day. What prompted you to want to begin a career in banking? Well, that’s the interesting part of the story. I had originally hoped to become a scientist, but the small town I moved to offered only a very basic science curriculum. 14 | The Show-Me Banker Magazine
After graduating from high school, I married a hog farmer and needed to find work to help support our household. I took a position at a small community bank — and from there, everything else unfolded. Tell us about the bank’s community investment efforts. Pony Express Bank is deeply committed to community banking, a dedication clearly reflected in its people. Employees actively support the surrounding communities by volunteering with more than 20 local organizations, and many of those employees also serve in leadership roles as board members or trustees. What is the bank’s biggest challenge in the area of internet banking/mobile banking? Older customer segments may face challenges navigating online and mobile banking platforms, making it more difficult to direct them to these channels for information and services. Keeping pace with the latest developments in digital banking is an ongoing effort, and staying ahead of evolving fraud risks adds another layer of complexity. Our entire team remains committed to supporting customers by promoting fraud awareness and providing guidance to help them bank safely and confidently. What’s your favorite thing about your bank/banking in general? This family-owned bank cares about its people in a way I’ve never experienced in all the years I’ve worked with financial institutions. They genuinely recognize and celebrate success, sharing good news across the team. Whether it’s a handwritten note of encouragement, a surprise giveaway or stepping in to support employees’ families during difficult times, their commitment is clear. There’s a true sense of family here, reflected in the many employees who have dedicated more than 25 years to Pony Express Bank. That kind of loyalty speaks volumes about the culture they’ve built. If you didn’t have a career in banking, what other career would you choose? At this point in my life, if I were to pursue something new, I would love to own a greenhouse or a garden nursery. I enjoy working with my hands in the soil and learning which plants thrive in different environments. For now, my husband Carl and I are focused on traveling internationally and exploring and tasting different cultures, and our goal is to visit all seven continents. We also enjoy spending time together at local sporting events with our blended family. The Show-Me Banker Magazine | 15
Leadership Division at the Capitol April 15 Jefferson City, MO 16 | The Show-Me Banker Magazine
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LEGAL EAGLE SPOTLIGHT SBA, DOJ Intensify PPP Enforcement Key Risks for Borrowers and Lenders By Dan Nelson and Amy Lewandowski, Spencer Fane LLP by the SBA through its COVID-19 relief programs, investigators are now taking their time in retroactively reviewing eligibility and ensuring full compliance moving forward. AUSA Investigations National DOJ components, 93 U.S. attorneys nationwide and internal SBA auditing teams are all looking deeper into borrowers’ eligibility for COVID relief funds, as well as lenders’ due diligence in issuing and monitoring PPP loans. And these requests are not limited to borrowers and lenders — even third parties have received letters requesting information, such as associations that provided PPP insight to their members when applying for funds. Investigations into borrower eligibility can be based on numerous factors: • Was the type of business eligible? (e.g., nonprofits, certain country clubs, etc.) • Did the business meet the definition of “small”? • Was the type of business eligible at the time it applied? (e.g., eligibility standards during first vs. second draw loans) • Did the business submit the required information? • Did the business abide by the SBA’s affiliation rules? (e.g., did applicants disclose any business affiliates?) • Were the PPP funds used properly? • Did the applicant submit accurate information? (e.g., did they submit the proper requested documents?) • Did the applicant still qualify at the time of any forgiveness application? • Was the amount of the PPP loan provided substantiated by truthful information? (e.g., was payroll inflated, etc.?) The SBA appears to be continually auditing PPP borrowers, requesting that they retroactively confirm information such as that just identified in the list, not only to ensure that businesses were eligible for relief from the outset, but also to audit whether they qualified for the loan amount issued and subsequently forgiven. Not only should borrowers be aware, but lenders also face ongoing scrutiny of these loans. While investigative agencies have been examining potential PPP borrower fraud since the inception of the program in early 2020, the DOJ has recently also begun investigating whether the financial institutions that operated as PPP lenders also abided by the applicable laws. Banks or other financial institutions that issued PPP loans were required to comply with certain While the COVID-19 pandemic may be in the not-so-distant past, investigations into lenders and borrowers who took out loans pursuant to COVID-19 relief programs persist. With ongoing scrutiny from the Small Business Administration (SBA), the U.S. Department of Justice (DOJ) and the SBA Office of the Inspector General (OIG), staying informed is critical. In January 2026, President Trump announced the DOJ’s new National Fraud Division focused on investigating and pursuing fraud charges and civil claims. With the SBA, DOJ and OIG making their way through the backlog of PPP loans, both borrowers and lenders should ensure ongoing compliance and be prepared to handle an investigative request from any of these entities. Most of us remember the confusion and uncertainty during the COVID-19 pandemic. Concerns about shutdowns, making payroll and navigating the “new normal” of stay-at-home orders — all while keeping businesses running — meant that new legislation needed to be implemented immediately, and companies had to act fast. While guidance at the time was confusing, with over $200 billion identified in potentially fraudulent loans disbursed 18 | The Show-Me Banker Magazine
obligations both at the time of application and must continue to do so throughout the life of the loan. Lenders who provide any SBA small business loans, which include PPP loans, have an ongoing duty to report any information that indicates fraud or illegal activity may have occurred in connection with an SBA loan. Potential fraud and knowledge of the same is not just limited to knowledge gained since issuing a loan; it includes what the lender knew from the day it submitted a PPP application on behalf of a borrower. In one federal case, a bank agreed to a settlement payment after being investigated for PPP fraud — a borrower had applied for a PPP loan falsely stating he had no criminal history, and the bank submitted the application even though it knew this statement was false. This should raise concerns for lenders whose employees may have overlooked what seemed to be small issues at the time of application but could now implicate hundreds of thousands or even millions of dollars in liability. Further complicating issues for PPP lenders are the differing standards for first draw and second draw loans. The guidance for first draw PPP loans was that lenders were “held harmless” as long as the lenders acted in good faith; they had no duty to verify PPP application information from the borrower. For second draw PPP loans, the guidance was that lenders were to perform a “good faith review” of the borrower’s calculations and supporting documents. Qui Tam Actions In addition to federal prosecutor and regulator scrutiny, PPP recipients also could be the subject of litigation without even knowing it. There have been a number of Qui Tam actions filed by private citizens who have taken it upon themselves to investigate potential PPP fraud in hopes of receiving a “finder’s fee” payout. Qui Tam actions are vehicles for private persons to bring claims under the False Claims Act on behalf of the government, asserting that third parties committed fraud. Qui Tam actions are initially sealed — meaning the defendants are not served or otherwise given notice that the litigation has been filed, and the case documents are not publicly available on the federal court’s ECF-Pacer document system until the government makes a decision regarding “intervention.” After receiving notice that a Qui Tam lawsuit has been filed, the government evaluates the lawsuit, deciding whether or not it wishes to “intervene” and take over the litigation. Qui Tam actions have been a primary driver of Civil Investigative Demand (CID) letters and requests for voluntary production issued by the government to companies and other entities who received PPP loans. Without having to conduct much or any investigation, a U.S. Attorney’s Office often sends out investigatory demands to named defendants in these sealed actions to gather information to evaluate whether to intervene in the lawsuit. Only later, at the time the government makes its intervention decision, is the case unsealed and the defendants are made aware they have been sued. Should the government choose not to intervene in the Qui Tam action, the private plaintiff can abandon or maintain its case, but without the benefit of the government footing their legal bills. False Claims Act Most Qui Tam actions are brought pursuant to the False Claims Act (31 U.S.C. § 3729, et seq.). In short, the FCA subjects to liability any person who knowingly presents a false or fraudulent claim for payment or otherwise knowingly submits a false record to a false claim. As related to PPP or other government-issued COVID relief funds, this means that FCA investigations generally focus on whether a business requested a PPP loan knowing it was not eligible, or an applicant provided falsified documents to make it appear eligible, to get a higher loan amount or otherwise abuse the PPP program. While most investigations are commenced to determine FCA liability, even a lender or borrower who is cleared of a potential FCA charge (after the government investigates and determines they applied in good faith) may not be out of the woods. There is still a question of eligibility; even if a borrower honestly believed they qualified for COVID relief, small oversights at the time of application could show otherwise. And this is something the SBA is following up on, regardless of whether there is any indication the borrower acted in bad faith. If it turns out funds were given to an ineligible borrower, that business could still face a multitude of consequences. For example, the government may require a borrower to pay the entire loan back, pay back amounts above the borrower’s eligibility threshold or discuss entering a settlement to resolve the matter, including potential liability for treble damages plus interest. I received a CID/letter from the SBA/ subpoena from an AUSA/other document request related to my PPP loan, EIDL loan or other SBA COVID relief funds. What do I do?! The good news is that receipt alone of a CID or other investigative request does not automatically mean that a Qui Tam action has been filed against a business, or that a loan repayment demand is imminent. Our team has worked with numerous DOJ components and U.S. Attorneys’ offices to identify the scope of inquiry and discuss limiting the amount of information and documents required to be produced, and we advocate for clients who were simply trying to stay afloat during unprecedented times. We also help work with borrowers who have concerns about their eligibility or the amount of loan received, and can assist in negotiations with the SBA. Even if your business has not received a formal inquiry, our team is available to advise — whether you are a lender who is questioning your ongoing duties, a borrower who wants to be prepared should an inquiry arise or have any other questions about ongoing PPP enforcement, we are here to help. As the government’s pandemic‑related enforcement work persists, preparation and clarity remain essential for both borrowers and lenders. Whether addressing a targeted document request, responding to a CID or evaluating internal compliance processes, early engagement and informed decision‑making can meaningfully reduce potential liability. Our attorneys can assist in developing an effective strategy tailored to the issues raised. The Show-Me Banker Magazine | 19
By Andy Arnold Arnold & Associates MIBA Lobbying Report By the time you read this, the 2026 session of the Missouri General Assembly will have concluded, and we will be turning our focus to the August primary elections. Working with the MIBA staff, on April 15, we hosted the MIBA Leadership Division at the Capitol. We met with the House Financial Institutions Committee chairman, Rep. Bill Owen, and the Senate Insurance and Banking Committee chair, Sen. Sandy Crawford, and also introduced the group to Speaker of the House Rep. Jon Patterson. On the legislative front, we were able to get several banking-related bills approved this year. Bills passed to date include: • HB 1870, sponsored by Rep. Lane Roberts, modifies the law relating to garnishments. Signed by Governor Kehoe. • HB 2423, sponsored by Rep. Philip Oehlerking, revises the Division of Finance’s ability to collect and deposit fees. Signed by Governor Kehoe. • SB 834, sponsored by Sen. Sandy Crawford, modifies the law and allows mortgage modifications without having to write a new loan. Awaiting Governor Kehoe’s approval. • SB 907, sponsored by Sen. Brad Hudson, creates the “Act Against Abusive Website Access Litigation.” Signed by Governor Kehoe. • SB 1142, sponsored by Sen. Brad Hudson, modifies provisions relating to “series LLCs.” Signed by Governor Kehoe. In addition to the bills championed by MIBA, the legislature passed HJR 173, sponsored by Rep. Bishop Davidson, that puts eliminating the state’s income tax to a public vote. While this was not a MIBA priority, it is one of the 90+ bills we actively tracked for MIBA during the 2026 session. And finally, a hearty thank you to Matt, Michelle and the entire MIBA team for their assistance this session in understanding the issues important to MIBA members. 20 | The Show-Me Banker Magazine
JUNE 24 Universal Banking Certification Series: Session IV Leadership Division at the Ballpark Virtual Kansas City, MO Virtual Essentials of Banking Series: Session VI Fundamentals of Business Cash Flow Series: Session I JUNE JULY JULY 17 22 Virtual Virtual UPCOMING EVENTS 2026 Community Bankers for Compliance 3rd Quarter Meeting AUGUST 13 Jefferson City, MO For more information contact Rebecca Young at ryoung@miba.net 16 The Show-Me Banker Magazine | 21
PORTFOLIO MANAGEMENT In With the New Introducing The Baker Group, ICBA Securities’ New Endorsed Broker-Dealer By Jim Reber, CPA, CFA, Managing Director of ICBA Relations, and Ryan Hayhurst, President, The Baker Group MIBA Endorsed Vendor Jim Reber: Ryan, what a difference a couple of months makes. Last fall, ICBA Securities’ board of directors asked management to study the depository fixed-income broker market and make a proposal for a relationship that would carry ICBA and its members into the future. From that, we identified The Baker Group as the first, best option. The board agreed, and after a couple of months of negotiations, we sealed the deal in early March. Tell us about The Baker Group and your multi-decade career with one firm. Ryan Hayhurst: The Baker Group was founded in 1979 by a community banker who saw a need for a firm that could help community banks manage their interest rate risk through investment portfolio management. Today, we have grown to one of the largest, independently owned, full-service broker-dealers serving community banks nationwide with a focus on education, asset-liability management and investment portfolio management. Much like how our clients are community banks, I like to think of us as a “community broker-dealer” focused on the needs of the customers we serve rather than an out-of-state owner that only cares about the bottom line. As for me, I joined The Baker Group in 1991 as a wet-behind-the-ears college intern, and I immediately fell in love with the people and culture that make up the Baker family. Thirty-five years later, I couldn’t imagine ever working for another company. Jim: Next, what can you tell us about Baker’s interest in and response to ICBA’s invitation to submit a proposal last year? Ryan: We were thrilled when ICBA reached out and asked us to submit a proposal to become the newly endorsed broker-dealer for ICBA Securities. As you know, The Baker Group was a finalist back in 1988 when ICBA selected its first endorsed broker, and unfortunately, we came in second place. But we didn’t give up. We developed new and better tools, we expanded our education platform, doing 50 to 70 events a year, and we focused on what community banks needed. Thirty-seven years later, the opportunity came around again, and we jumped on the chance to submit a proposal. Community banks are the lifeblood of America, and this endorsement will allow us to take our shared mission of serving and supporting community banks to an even bigger audience. Jim: Many of our readers know there has been another twist to this ICBA Securities-Baker Group arrangement, which is that I joined the Baker team effective April 1. I, too, have had a terrific run with one broker. I started as an ICBA Securities sales rep in 1992 and succeeded the legendary C.J. Pickering as president and CEO in 2005. ICBA was a fantastic employer, and I got the best of both worlds in my view: a position in the bond business where I’ve got some history (notoriety?) and continued collaboration with some of the best in the business among all three ICBA pillars: advocacy, innovation and education. So, there’s a lot to be said for continuity. (And I’m working on the “we” and “they” pronouns as I transition, so be patient.) Ryan: I can’t tell you how excited we are to have you join the Baker team. Your experience, reputation and integrity are unparalleled in this industry. In fact, once the announcement was made that we would become the new endorsed broker for ICBA Securities, the very first question every banker and state association asked me was, “Is Jim Reber coming to Baker?” I am proud to say, “Yes!” Jim: We should also tell our readers they’ll be seeing some changes to this Portfolio Management column. One of the many reasons Baker was invited to contract with ICBA is its deep bench of strategists and speakers. What are your plans for this column and what can you tell us about Baker’s commitment to community bank bond education? Ryan: Education is one of our pillars, along with investment portfolio and asset-liability management. We remain committed to continuing our long history of providing in-person and virtual education programs designed specifically for community banks. 22 | The Show-Me Banker Magazine
As for this column, we plan to continue your legacy of providing valuable (and entertaining!) investment insight, but through a range of contributors. You’ll be hearing from not only me but also several other members of our Financial Strategies Group. Jim: Let’s not forget about Baker’s capacity to partner with ICBA’s state affiliates, which was a matter of high rank in the selection process. Ryan: That’s right. We understand just how important state banking associations are to community banks. We are bringing endorsements from ICBA state affiliates in Illinois, Texas, Indiana and Alabama into the mix, so we know what it takes to work with these associations as they fight for community banks in their state. We have partnered with state banking associations for more than four decades to provide industry-leading education and financial support, and we look forward to working with all 34 state associations that endorse ICBA Securities. Jim: Very good. I am honored that The Baker Group offered me this position, and I intend to remain visible to ICBA members and attend conventions whenever practicable. In the near term, my objective is to get Baker integrated into the ICBA extended family as efficiently as possible. I’m beyond excited about this new chapter for ICBA Securities and The Baker Group. Ryan: I couldn’t agree more, Jim. Welcome aboard! Jim Reber, CPA, CFA, is managing director of ICBA relations at The Baker Group. Ryan Hayhurst is president of The Baker Group, ICBA Securities’ endorsed broker-dealer. BANCMAC COMMUNITY BANC MORTGAGE CORP. YOUR COMMUNITY BANK MORTGAGE PARTNER bancmac.com mortgages@bancmac.com 888.821.7729 | NMLS# 571147 BancMac provides correspondent and wholesale lending and is your Community Bank Mortgage Partner to help your financial institution originate fixed-rate secondary market loans including: PROGRAMS • Conventional Loans • USDA Rural Development Loans • Rural Living (Hobby Farm) Loans • VA Loans • Jumbo Loans • FHA Loans OUR PARTNERS RECEIVE: • Superior Service & Competitive Pricing • No Minimum Volumes • Significant, Non-Interest Fee Income • Non-Solicit Protections & More The Show-Me Banker Magazine | 23
Branson Bank Promotes Norma Desrochers to AVP, Senior Business Relationship Banker Branson Bank is honored to announce the promotion of Norma Desrochers to assistant vice president, senior business relationship banker, in recognition of more than 29 years of banking experience serving her community. In this elevated role, Desrochers will continue to leverage deep expertise in senior-level retail banking products and services, with a strong focus on supporting business clients. Throughout her career at Branson Bank (over 22 years), she has consistently demonstrated a commitment to delivering tailored financial solutions, building lasting client relationships and driving growth within the business banking segment. “Norma exemplifies the dedication, knowledge and client-first approach that defines our organization,” said Katie Hodges, EVP, chief operations officer. “This promotion reflects not only her professional achievements but also the trust and respect she has earned from customers, colleagues and the community.” Beyond professional accomplishments, Desrochers is deeply committed to community engagement. As a lifetime resident, her involvement underscores a belief in giving back and strengthening the community in which she was born and raised. Her involvement includes serving on the boards of the Hollister Area Chamber of Commerce, the Hollister Chamber Leading Ladies, the Branson-Hollister Senior Center and the Taney County Tax Board. Last fall, she completed the Branson Lakes Area Leadership Program. Desrochers is a proud supporter of Kirbyville and Hollister Schools. She enjoys going to flea markets and spending time with her husband, Roland, and their children and grandchildren. News From You Branson Bank Promotes Stacy Cash to AVP, Business Services & Operations Officer Branson Bank is pleased to announce the promotion of Stacy Cash to assistant vice president, business services & operations officer. In this role, Cash will continue to play a critical role in delivering efficient, secure and innovative services to business customers. Her expertise ensures that business customers receive reliable operational support and a seamless digital banking experience. With more than 16 years of experience in the banking industry, Cash has developed a deep understanding of customer service, digital operations and evolving financial technologies. Additionally, she has earned the Accredited ACH Professional (AAP) designation, demonstrating her commitment to excellence in electronic payments and ACH services. “Stacy consistently demonstrates a strong eagerness to learn and grow, which has made a meaningful impact on our operations team and the customers we serve,” said Katie Hodges, EVP, chief operations officer. “Always willing to step in, support others and find solutions, Stacy’s commitment to excellence makes her a valued asset to our organization. We are excited to see her thrive in this expanded role.” Cash serves as an ambassador for the Hollister Chamber of Commerce, attending ribbon cuttings and monthly meetings, and volunteering for community events. She enjoys a variety of crafts, scrapbooking and spending time with her husband, Tracy, and son, Alex. 24 | The Show-Me Banker Magazine
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