2026 ISSUE 4 2026 MIBA SUMMER BOARD MEETING July 13-14 2026 Annual Convention & Expo
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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™. 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 Strong Management, Strong Relationships and a Strong Future 5 36th Annual Scholarship Auction Browse and Bid for a Great Cause! 6 FROM THE TOP Redefining Succession as Legacy 7 FLOURISH Service: The Heart of the Community Bank Difference 8 BACKGROUND ON A.W. Spellmeyer President and CEO of First Bankers’ Banc Securities 11 49th Annual Golf Tournament Monday, Sept. 14, 2026 12 MEET YOUR MISSOURI BANKER Jacob Schmucker Head Personal Banker Manager, Peoples Bank & Trust 14 2026 MIBA Summer Board Meeting July 13-14 16 LEGAL EAGLE SPOTLIGHT The Debanking Minefield Navigating Fair Access in 2026 19 REGISTER TODAY 49th Annual MIBA Convention & Expo The Best Place to Connect With Missouri Community Bankers 20 49th Annual MIBA Convention Preview Join Us for Another Exciting Line‑Up of Speakers and Events! 21 Thank You, Early Convention Sponsors 22 Before the Convention: The Conversations Worth Having 24 Upcoming Events 2026 25 MIBA Lobbying Report 26 Three Questions Banks Should Ask About Moving Deposits Off Balance Sheet It’s a Strategic Decision — Not a Reaction 28 SAVE THE DATE 2026 Women in Community Banking Seminar November 4-5, 2026 29 News From You 30 Mean Reversion: Bond Yield Relationships Are Looking Familiar, Finally 32 Welcome, New Associate Members 32 SAVE THE DATE 17th Annual Security Conference Sept. 30-Oct. 2, 2026 33 2026 PAC Honor Roll 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 14 30 12 7 The Show-Me Banker Magazine | 3
PRESIDENT’S MESSAGE STRONG Management, STRONG Relationships and a STRONG Future Curt Brumley MIBA President, Community Point Bank Management and operations of banks have significantly changed over the years, driven by evolving consumer habits, new regulations and technological improvements. Today’s management and operation strategies drive every aspect of the business. Bank management involves planning, organizing, leading and controlling the bank’s resources to achieve the bank’s objectives. These objectives are driven by the board through the president and management team and could be for a specific department or a bank-wide initiative. One of the main functions of management is financial management. Every bank may have a different approach, but all of them lead to the same goals: profit, adequate capital, liquidity management, expense control, setting deposit and loan rates, etc. Proper budgeting and financial planning are needed to operate efficiently and withstand changing economic conditions. 4 | The Show-Me Banker Magazine
Customer relationship management is another important area in operations. Community banks rely on strong customer relationships and personalized services to build customer trust and loyalty. Another significant part is risk management, which protects the bank from losses, whether from credit risk, operational risk, market risk or the ever-increasing fraud/cybersecurity risk. These risk areas are taking up more time and requiring more attention every day. The use of technology has changed substantially since I started my career. It has become an integral part of our lives. Its benefits include efficiency, quicker transactions, improved data security, and allow customers to access accounts and services through various methods instead of driving to the bank. The use of AI, if it hasn’t already, will change many areas of a bank. Fraud and cybersecurity measures are paramount to protecting the bank against losses and the exposure of customer information. The final area I want to mention is human resource management. Recruiting and maintaining qualified staff is important to the bank’s overall success. To accomplish this, a bank must have competitive benefits, provide ongoing training and invest in employees’ personal development. Qualified and motivated staff members are better equipped to meet customer and bank needs. Bank management and operations generally require a balanced approach that integrates sound practices, effective leadership from all departments, a customer-focused approach, efficient operations and strong risk management. I hope everyone plans to attend and is geared up for a great 49th Annual Convention and Expo, Sept. 14-16, 2026, at The Lodge of Four Seasons. Organizing and holding a great convention year after year is not an easy task. I am very appreciative of Matt, Michelle, Jessica and Rebecca for the efforts they put into making each convention a success! I also want to say thank you to the speakers and vendors who will be attending. Your time, knowledge and products help all of us better navigate the daily world of banking. With this being my final message, I want to take the opportunity to say that serving as the association’s president over the past year has been a great honor. I want to thank the prior chairmen of the board, the prior presidents, the MIBA Board of Directors and all the member banks for their support. To Doug Fish, immediate past president, thank you for your past and continued service. To Chuck Gnuse, I know the association will be in good hands next year, as you step up as our new president. Looking forward to seeing everyone in September at the 49th Annual Convention. 36th Annual Scholarship Auction Browse and Bid for a Great Cause! In just a few short months, we will gather with our MIBA membership, family and friends for another exciting Convention & Exhibition. This year’s 36th annual MIBA Scholarship Auction will take place on Tuesday, Sept. 15, at The Lodge of Four Seasons. We hope you are already thinking about the items you’ll donate to this worthy cause! On Tuesday during the Convention, the Exhibit Hall will close at 2:00 p.m., and the MIBA Scholarship Silent Auction & President’s Reception will begin at 4:30 p.m. All registered bankers and exhibitors are invited and welcome to join in the fun in support of the next generation of Missouri independent bankers. If you have an item to donate to the auction, please contact the MIBA offices at (573) 636-2751 to request a donation form. For more information, visit miba.net. Donations to and purchases made at the auction are not deductible for federal income tax purposes. The Show-Me Banker Magazine | 5
In my experience, community banks sell for one of the following reasons: Board succession has not been strategically planned, executive staff and leadership succession have not been strategically planned, or the market has taken a turn. Two of the three focus on preparing bank leaders for the future, making succession planning a critical component of a community bank’s long-term viability. But to do it well, succession planning takes work. It requires hard, transparent discussions with the board and executive staff. It relies on open conversations about retirement horizons, and it means the careful cultivation of the next generation of community bankers. A speaker at last year’s Independent Community Bankers Association of New Mexico annual meeting summed up this concept with a visual: the quarterback backup chart. It showed Patrick Mahomes, the quarterback for the Kansas City Chiefs, and three backup quarterbacks, along with the skills they needed to cultivate to replace Mahomes. Developing a Legacy It’s that level of transparency and thoughtful work that needs to go into succession planning for community banks. We need to equip our teams with the experiences they need to get to the next level. Succession planning is about investing in others, FROM THE TOP Redefining Succession as Legacy Alice Frazier Chair, ICBA because what we invest in others is the legacy we leave our banks. When we redefine succession planning as creating a legacy in people, it changes how we view it. Our work in cultivating the next generation means that we are building our bench and preparing our backup quarterbacks to get in the game. It’s about being open and strategic in how we ensure the future is secured. The root word of succession is success, which explicitly tells us that it’s our job as leaders to ensure our banks continue to thrive. So, as you read this issue, consider ways you can empower your teams. Get them engaged with ICBA Advocacy activities. Expose them to the sessions offered by ICBA Innovation. Use ICBA Education to support career development planning. Each of these efforts helps to shore up the future of your bank through its people. At the end of the day, instead of thinking about succession planning as a chore, let’s look at it in the context of the legacies we’re leaving. Our job is to develop the people who make our banks flourish today and will ensure our legacy into the future. Quote of the Month “Your legacy is not leaving something for people; it’s leaving something in people.” — Peter Strople 6 | The Show-Me Banker Magazine
FLOURISH Rebeca Romero Rainey President and CEO, ICBA In the months that have passed since we came together at ICBA LIVE, I’ve been reflecting on one key sentiment that came across loud and clear: Community banks have a unique and profound impact on the lives of those we serve. At LIVE, retired U.S. Army Staff Sergeant Travis Mills, a quadruple amputee, shared his story of perseverance and courage, inspiring everyone in the room. But an electric current shot through us all when he indicated that the work he does today to support families of military veterans has been made possible by his local community bank. Everyone sitting in the crowd made a connection in real time that the work they do is vital to helping humanity. That truth is reflected in the way in which we conduct business. One of my favorite things to do while traveling is to meet with bankers in their community. The story is the same in every market: Community banks go the extra mile to serve. I recently met with a banker in Colorado who recounted stories of the businesses his bank supported. From the college and hospital to local restaurants and farmers, he knew their histories and current challenges. Community bankers might take this approach for granted, but this is the side of relationship banking that makes the difference. The difference is the relationships, the history and the desire to invest and support the long-term viability of the community, one small business at a time. Lenders of Choice Shortly after this visit in Colorado, I had a meeting with the head of the National Economic Council. We went back to the data: Community banks fund 60% of U.S. small business loans and 80% of the banking industry’s agricultural loans. While this aggregate information tells a story, it doesn’t explain that we do it because it’s what’s right for our communities. That’s why leaders need to hear the stories of community bank service. Hearing them reveals, without a doubt, that community banks are the hearts of their communities, and their communities have their hearts. That love for what we do and who we serve transcends day-to-day business to ensure we make a real difference. At ICBA, this is what we’re fighting for and standing up to support through advocacy, education and innovation. We strive to bring you the solutions that help you make a difference every day. Just as LIVE’s “Anchored in Purpose” theme said, the work community banks do matters, and we must continue amplifying that message for all who need to hear it. Service: The Heart of the Community Bank Difference The Show-Me Banker Magazine | 7
BACKGROUND ON A.W. Spellmeyer Some careers begin with a carefully planned interview. A.W. Spellmeyer’s began with a poker game. While attending a Christmas party shortly after graduating with an economics degree, A.W. found himself sitting across the poker table from Jim Lanigan, one of his father’s fraternity brothers and a leader at what was then First St. Louis Securities, now known as First Bankers’ Banc Securities (FBBS). A.W. had interviewed for a position at the brokerage just weeks earlier without much success. But after taking James’ money during the card game, he earned something far more valuable — a second look. That unexpected opportunity led him to join the company in July 2004. More than two decades later, the one-time bond trader now serves as president and CEO of FBBS. Under A.W.’s leadership, the company has grown into one of the nation’s premier fixed-income partners for community banks. Throughout the journey, A.W. has remained grounded in the culture that first attracted him to the organization — one built on integrity, relationships and putting community banks first. We sat down with A.W. to discuss his career, the evolution of FBBS and how the company is helping community banks navigate today’s rapidly changing financial landscape. The following are excerpts from our conversation. President and CEO of First Bankers’ Banc Securities
Please tell us a bit about what you do at FBBS. Every day is a little different, and that’s one of the things I enjoy most. At a high level, I’m responsible for setting the strategic direction of the company, but because we’re still relatively small, I get involved in just about everything. That includes sales, trading, compliance, personnel, customer relationships and evaluating new technology. We oversee an investment portfolio accounting platform for a large number of institutions, so we’re constantly reviewing our data, improving our platforms and making sure we’re providing the best tools possible for our clients. I also spend a lot of time traveling to banking associations and visiting customers. Since we’re owned by multiple bankers’ banks, I’m on the road quite a bit. And if one of our traders is out, I still get to jump back into trading bonds, which is honestly still my favorite part of the job. People ask what a typical day looks like, and the answer is that there really isn’t one. If something needs attention, whether it’s strategy, operations or helping a client solve a problem, I’m involved. What has been the most rewarding part of your career so far? Without question, it’s seeing other people succeed. Whether it’s someone here at FBBS that we’ve hired and helped develop or someone at one of the community banks we work with, watching people grow professionally is incredibly rewarding. I used to teach at banking schools, and now I’ll run into people who started as first-year students, and they’re leading departments or running banks today. Seeing that progression is really satisfying. As CEO, there’s another aspect that has become meaningful to me that I probably didn’t fully appreciate before. We have more than 30 employees here, and I am ultimately responsible for them — their mortgages, their kids’ college tuition, their families — and I don’t take that lightly. Until you sit in this chair, you don’t fully understand what it means to have that many people depending on you. You don’t want to let them down. Being able to provide opportunities for people and watch them build successful careers has easily been the most rewarding part of my job. How has FBBS changed since you started working there in 2004? When I started, we were independently owned by a handful of partners. That changed when the company became part of the bankers’ bank ownership group, and that’s probably been the biggest corporate change we’ve experienced. Beyond that, the business itself has evolved dramatically. Twenty years ago, fixed-income brokerage was much more straightforward. Banks bought bonds, sold bonds and that was largely the conversation. Today, if you’re going to compete, you have to bring a complete toolbox. Community banks expect much more from their partners. Along with brokerage services, they need bond accounting, asset/liability management tools, interest rate risk modeling, scenario analysis, balance sheet strategies and sophisticated analytics. They want to know not only what’s happening today, but what could happen tomorrow under multiple scenarios. Technology has become just as important as relationships. Relationships still open the door, but the data, software and analytics have to back it up. Ultimately, our success depends on the success of the banks we serve. If they’re not successful, we’re not successful. That mindset has pushed us to continue expanding our capabilities and finding new ways to help banks compete. What sets FBBS apart from competitors? It starts with who owns us. We’re owned by bankers’ banks, and those bankers’ banks are owned by community banks. That creates a completely different perspective than most firms in our industry. The people serving on our board are presidents of bankers’ banks and leaders of community banks. Everything we do ultimately flows back to helping community banks succeed. I also think our size works to our advantage. We’re large enough to provide the same sophisticated services offered by much bigger firms, but we’re still small enough to be incredibly responsive. If a customer needs something, we’ll jump on a plane, hop on a call or build a solution if one doesn’t already exist. We’re not interested in telling customers why something can’t be done. We’d rather figure out how to make it happen. If one bank needs a new tool, chances are another bank will benefit from it too. That’s how many of our solutions have been developed over the years. The Show-Me Banker Magazine | 9
We also take being good stewards seriously. Every dollar we spend ultimately belongs to our owners, and their owners are community banks. That creates a level of accountability that’s hard to replicate elsewhere. At the end of the day, we want to do things the right way, be responsive and deliver results. How can FBBS help banks manage the ever-changing pressures of today’s market? Community banks are facing challenges from every direction — changing regulations, interest rate volatility, liquidity concerns, technology and now AI. One advantage we have is that we’re connected to community banks across the country. We hear what’s happening during examinations, what regulators are emphasizing and where banks are finding success. That gives us a broad perspective that we can share with clients. We’ve continued investing heavily in our technology as well. Today, we can provide sophisticated investment analyses, interest rate risk modeling, municipal credit reviews, balance sheet strategies and bond accounting. We also expanded into funding services by adding an in-house brokered funding desk, allowing us to help banks manage both sides of the balance sheet. We’ve also introduced loan purchasing capabilities, giving banks additional flexibility as market conditions change. Our goal has always been to become a true solutions partner. When a banker calls us with a challenge, we want our first answer to be, “Yes, we can help.” If we don’t already have the answer, we’ll find it. Between our team and our relationships with regulators, bankers’ banks, state banking commissioners and community bankers throughout our network, chances are someone has encountered that challenge before. That’s one of the biggest advantages of being deeply rooted in the community banking industry. Is there anything exciting on the horizon for FBBS that you’d like readers to know about? One area we’re investing heavily in is artificial intelligence. Like everyone else, we recognized that AI was changing rapidly and decided to embrace it early. We evaluated multiple AI platforms and have spent the past year testing, refining and building practical applications into our business. The key is using AI responsibly. We don’t view it as replacing people. We view it as making talented people even more effective. With the proper guardrails in place, AI allows our analysts to process enormous amounts of data more efficiently, freeing them to focus on higher-value work. We’ve also developed our own internal platform by integrating years of customer data, CRM information, reporting tools and portfolio analytics into a single system. That allows our team to create custom peer groups, generate reports, analyze customer relationships and identify trends much faster than before. Looking ahead, we’re expanding those capabilities even further. Our goal is to use AI to leverage historical market data, gather call report information and analyze economic indicators to identify opportunities that may help community banks make better investment decisions. It’s another tool — not a replacement for experience — that can provide valuable insights when combined with knowledgeable professionals. Any final thoughts? The longer I’ve been involved with community banking, the more I’ve come to appreciate organizations like MIBA. Early in my career, I didn’t fully appreciate everything associations do behind the scenes. Today, I see just how important they are. They advocate for community banks and provide education, leadership development and, maybe most importantly, opportunities for bankers to connect with one another. Community banking has always been built on relationships. Bankers may compete in the marketplace, but they’re also colleagues who share ideas, learn from one another and work together to strengthen the industry. That collaboration is one of the things that makes community banking unique. At FBBS, we feel closely aligned with that same mindset because of who owns us and who we serve. And if I were going to leave readers with one piece of advice, it would simply be this: Try to outwork everybody, and you’ll usually end up just fine. 10 | The Show-Me Banker Magazine
49th Annual Golf Tournament Monday, Sept. 14, 2026 The Cove A Robert Trent Jones Sr. Signature Golf Course The Lodge of Four Seasons Lake Ozark, MO The tournament tees off at 10:00 a.m. The entry fee is $175 per person and includes two mulligans, breakfast with bloody mary and mimosa bar, lunch, refreshments, cart and green fees. You must be a fully registered convention attendee or exhibitor to participate in the tournament.
MEET YOUR MISSOURI BANKER Where are your main bank and branches located? What is the market like? Peoples Bank & Trust is headquartered in Troy. We have nine branches total (soon to be 10) located in Lincoln, St. Charles and Pike counties. We serve a variety of markets, from rural, agriculture-based towns to some of the fastest-growing areas in Missouri. What is something unique about your bank? We recently celebrated 100 years in business. How did you get started in the banking business? My first job in banking was as an assistant manager for one of the large national banks. What is the most important thing you have learned from this career so far? I’ve learned a lot about people in general. There are a lot of different personalities out there, and a lot of different expectations among customers and employees. In this business, you need to know how to talk to everyone and understand what’s important to them. Jacob Schmucker Head Personal Banker Manager, Peoples Bank & Trust 12 | The Show-Me Banker Magazine
What is the most interesting thing you have learned from your transition to the banking industry? The most interesting thing I’ve learned is the difference in approaches to banking that community banks take compared to the big national banks. Tell us about your bank’s community investment efforts. Our community involvement is everything. It’s so important to support the communities in which we work and live. It’s the primary engine driving trust, growth and long-term financial stability. What is the bank’s biggest challenge in the area of online/mobile banking? The biggest challenge in mobile banking for us is mitigating fraud risk. What’s your favorite thing about your bank or banking in general? My favorite thing about Peoples Bank & Trust is the positive impact we have on each community in which we do business. The people who work here are great, too. If you didn’t have a career in banking, what other career would you choose? My dream job is to be a farmer. What prompted you to want to begin a career in banking? I worked in the restaurant business for a long time before I began my banking career. That’s a tough business to be in when you’re starting a family. It’s a lot of nights, weekends and holidays. It was important for me to make a career change so I could be there for the times that matter as a father. The Show-Me Banker Magazine | 13
2026 MIBA Summer Board Meeting July 13-14 JEFFERSON CITY, MO 14 | The Show-Me Banker Magazine
Thank You, Sponsors! HOSPITALITY SUITE SPONSOR GOLF LUNCH SPONSOR The Show-Me Banker Magazine | 15
LEGAL EAGLE SPOTLIGHT The Debanking Minefield Navigating Fair Access in 2026 By Yana Rusovski and Kirstin Kanski, Spencer Fane LLP Few regulatory shifts move this fast. What started as a Fair Banking Executive Order in August culminated in a final rule that eliminated reputational risk from bank supervision, which took effect on June 9, 2026. And in between, the Office of the Comptroller of the Currency (OCC) released preliminary findings of its investigation into nine of the largest U.S. banks; the Federal Trade Commission (FTC) issued warning letters to major payment networks; the Small Business Administration issued a mandate to cease debanking, conduct reviews, report findings and reinstate customers; and a growing body of fair access state laws is being proposed despite industry calls for federal preemption. The executive order targeted the prudential regulators, requiring the removal of reputational risk and any other language in supervisory documents that could lead to “politicized or unlawful debanking,” defined as any restriction on access to services based on political or religious beliefs or on disfavored lawful business activities. The order underscored that all banking decisions must be made “on the basis of individualized objective and risk-based analyses.” The banking industry publicly welcomed the call for removal of reputational risk, noting it is in all “banks’ best interests to take deposits, lend to and support as many customers as possible” in a news release from the American Bankers Association in August 2025. Given a recent wave of U.S. Department of Justice (DOJ) subpoenas to banks, it remains important to understand the landscape shift, risks and impacts. Congress Responds with Proposed Fair Access Legislation Congress has neither prioritized nor had the need to codify standards governing access to the banking system. A bank’s relationship with customers is primarily one of contract and choice. The supervisory concept of reputational risk is nothing new. It originated in the 1990s as part of the OCC’s introduction of risk-based supervision, and was not publicly reported to be used to influence access to financial services until what later became Operation Choke Point. The concept of “fair access” is not new either, having first appeared as part of the Dodd-Frank Act, when Congress added to the OCC’s oversight responsibilities “fair access to financial services.” Despite prior efforts — including the OCC’s 2021 proposed fair access rule — the OCC never published a final rule implementing its “fair access” mandate until now. Now, however, in the wake of Operation Choke Point 2.0, Congress appears to be moving more quickly toward a permanent solution. Legislatively, two bills would codify the principles of fair access: the Financial Integrity and Regulation Management (FIRM) Act, which would eliminate reputation risk, and the Fair Access to Banking Act, which would require impartial, individualized, risk-based analysis in decision-making. Of the two, only the FIRM Act has been reported out of committee in both chambers; the Fair Access to Banking Act remains in committee. The industry has published its own Federal Fair Access Principles for Congress to consider as part of any legislative solutions, emphasizing the need for banks to maintain autonomy in pricing, products, risk and business decisions to remain competitive. Agency Rulemakings Remove Reputational Risk and Drive BSA/AML Reform The OCC and FDIC’s joint final rule wholesale eliminates “reputational risk” from bank supervision. The rule defines reputation risk as any risk to public perception “not clearly and directly related to the financial or operational condition of the institution” and prohibits both agencies from using it as a basis for any adverse supervisory action. This includes MRAs, examination criticism or pressure to close accounts. The Federal Reserve removed reputational risk from its examination programs in June 2025 and issued a parallel proposed rule in February 2026. 16 | The Show-Me Banker Magazine
The rule goes further than removing a risk category by barring examiners from requiring or encouraging institutions to terminate customer relationships based on political, social, cultural or religious views; constitutionally protected speech; or lawful but politically disfavored business activities. The rule also includes an anti-evasion provision: Examiners cannot reroute reputational risk concerns through compliance, operational or other risk categories as a workaround. Alongside the rule, the OCC and FDIC are also jointly working to finalize a new definition of “unsafe or unsound practice” that would codify, for the first time, a regulatory definition of “unsafe or unsound practice” under Section 8 of the Federal Deposit Insurance Act, tethered to the core concept of material harm to an institution’s financial condition or material risk of loss to the Deposit Insurance Fund. The era of supervisory actions grounded in public perception concerns has ended. In addition, on April 7, 2026, the Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking to “fundamentally reform” AML/CFT obligations under the Bank Secrecy Act and the Anti-Money Laundering Act of 2020, which is anticipated to be a significant overhaul of program requirements. Aligned with the new “unsafe or unsound” definition, Secretary of the Treasury Scott Bessent stated that the goal is not to measure success “by the volume of paperwork,” but rather by the “ability to stop illicit finance threats.” A well-designed BSA/AML program should align with the principles of fair access to banking services and require individualized, documented decisions in each instance. The challenge that has arisen is when institutions implemented “de-risking” strategies that resulted in exiting wholesale categories of industries or sectors based on “risks” that were not individual to a particular customer. A 2023 U.S. Department of the Treasury report confirmed that many de-risking decisions were “indiscriminate” and “overly broad,” driven by category-level judgments that bore little relationship to actual financial crime risk. The OCC issued guidance in September 2025, further reminding institutions that Suspicious Activity Report (SAR) filings must be grounded in concrete evidence of suspicious activity. Active Enforcement Investigations Underscore Need to Understand Impact A reported wave of recent subpoenas issued by the DOJ to financial institutions is a reminder that all institutions should understand how the removal of reputational risk impacts both current operating procedures and documented, historical risk-based decisions. At a minimum, banks should: 1. Confirm no remnants of reputational risk, categorical or industry-based risk-tiers or escalation requirements exist within policies and procedures (e.g., political, religious, ESG-based criteria) for whether a customer qualifies for bank services; 2. Update policies and procedures, if needed, to require individualized decisions with a focus on impartial and financially based metrics and criteria; 3. Confirm procedures are in place to comply with the Right to Financial Privacy Act when responding to government requests for information; The Show-Me Banker Magazine | 17
4. Understand if accounts were closed or services denied historically based on policies and procedures that would not conform with the new rule and updated guidance, and evaluate a scoped review that includes customer complaint data and critically evaluating the impact of SAR filing activity on account terminations; 5. Brief executive management and the board on impacts and risks; the OCC has advised that findings related to debanking activity can impact licensing, Community Reinvestment Act evaluations and acquisitions; 6. Track ongoing state laws imposing heightened fair access standards that may exceed federal requirements. So, what is the likely subject of the DOJ’s investigation? The DOJ subpoenas follow a task force launched by the U.S. Attorney’s Office for the Eastern District of Virginia to combat “illegal debanking,” which the task force defines as the denial of financial services for political views, religious beliefs or lawful activities. “Debanking” determinations may result in enforcement actions if determined by regulators to amount to unlawful discrimination practices in violation of fair lending or civil rights statutes, such as Title VI of the Civil Rights Act of 1964, the Equal Credit Opportunity Act (for credit transactions) and the Fair Housing Act (if related to mortgages). The DOJ also has broad, civil enforcement authority for a variety of underlying criminal (fraud) activity under Section 951 of the Financial Institutions Reform, Recovery and Enforcement Act of 1989. The investigations likely build on preliminary findings released by the OCC last year, which stated the OCC’s position on debanking activities undertaken by nine of the nation’s largest banks. The OCC found that between 2020 and 2023, each institution maintained policies that restricted or escalated review of customers in certain sectors (e.g., oil and gas, coal, firearms, private prisons, payday lending, tobacco, political action committees and digital assets). In most cases, the stated basis was reputational risk or values-alignment criteria rather than documented financial or legal risk. The OCC characterized the decisions as inappropriate distinctions drawn among customers based on lawful business activities. The OCC reported that the same or substantially similar policies were in place at every bank it reviewed and stated that it is working through nearly 100,000 pending consumer complaints to identify further instances of political or religious debanking. In remarks accompanying the rule, Comptroller of the Currency Jonathan Gould stated the ongoing investigation should “shine a spotlight on the actions of agencies and certain banks.” In March 2026, the enforcement perimeter may have extended to payment processing when the FTC issued public warning letters to the largest payment processors, putting them on notice that facilitating member institutions’ debanking practices may itself violate the FTC Act. Judicial and State Law Developments There has not been much occasion for courts to develop precedent on an individual’s “right” to banking services, which exists nowhere in the Constitution or federal statute. The D.C. Circuit Court has previously recognized a due process liberty interest in bank account access in a case brought by payday lender trade associations arising from Operation Choke Point 1.0. And in 2024, in a case brought by the National Rifle Association against the superintendent of the New York Department of Financial Services, the U.S. Supreme Court unanimously held that a government entity’s “threat of invoking legal sanctions and other means of coercion” against a third party, including financial institutions, can violate the First Amendment if used as a means of suppressing disfavored speech. Following the U.S. Supreme Court’s decision, it is now likely considered “clearly established” that a regulator cannot use oversight tools such as rating downgrades, fines, or enforcement to cause an institution to suppress speech protected by the First Amendment through activities such as denying access to banking. There are two pending “debanking” cases in the Southern District of Florida brought by entities affiliated with the Trump family against Capital One and JPMorganChase; neither case has proceeded to a merits determination or resulted in a published opinion. The legal claims raised by the plaintiffs in each case pursue a variety of state law theories only: asserting violations of consumer protection statutes in North Carolina, Nebraska, New Jersey and Minnesota against Capital One, while asserting state law claims of trade libel, Florida’s Unfair and Deceptive Trade Practices Act, enforcement of the Deposit Account Agreement and breach of good faith and fair dealing against JPMorganChase. Whether any of the pleaded theories will hold water, survive motions to dismiss or result in judicial opinions at all (as opposed to arbitrated) remains to be seen. Meanwhile, the states of Florida, Tennessee and Idaho have each enacted fair-access statutes, and several additional states have proposed or have pending similar laws. For institutions operating nationally, this creates a compliance map that cannot be satisfied by a single federal policy, because state-specific notice and documentation requirements must be addressed on a jurisdiction-by-jurisdiction basis. Although similar, the three enacted regimes differ in scope and mechanics. An Era of Fair Access Begins as Debanking Sunsets The momentum is strong, and the path is clear for Congress to codify how access to the banking system is to be determined. Now that “reputational risk” has been sunset, it remains important for institutions to evaluate how operating procedures and account decisions will hold up in the new era of “fair access.” 18 | The Show-Me Banker Magazine
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.
49th Annual MIBA Convention Preview Join Us for Another Exciting Line‑Up of Speakers and Events! SEPTEMBER 14-16, 2026 MONDAY Golf Tournament, Exhibitor Reception and Tailgate Party Kick off Convention on Monday, Sept. 14, with MIBA’s Annual Golf Tournament at The Cove, a Robert Trent Jones Sr. Signature Golf Course.. The tournament begins with a 10:00 a.m. shotgun start. That evening, join us from 4:30-7:00 p.m. for our Opening Exhibitor Reception in Campana Hall. This year’s tailgating theme will get everyone ready for Monday Night Football as the Kansas City Chiefs take on the Denver Broncos! Wear your favorite football attire, visit with exhibitors, enjoy game-day food and beverages, and catch the pregame show on the big screen. After the reception, grab dinner with friends, colleagues, or exhibitors before heading to MIBAR, where Monday Night Football will be playing on every TV. Enjoy our halftime entertainment featuring My Friend Mike, along with your favorite game-day snacks, cocktails, live music and late-night fun. TUESDAY General Session, Expo and Scholarship Auction Tuesday’s General Session features an outstanding lineup of speakers, including ICBA Secretary Doug Parrott, our 3rd Annual ThinkTECH Showcase, Montana State Auditor and Commissioner of Securities and Insurance James Brown and more. Spend the afternoon exploring the Expo and bidding on exciting items during the MIBA Scholarship Silent Auction. Tuesday evening, join us for the President’s Reception & Dinner, featuring our popular Lobster Fest as we recognize MIBA’s incoming 2026-2027 officers. The evening concludes with the always-entertaining MIBA Scholarship Live Auction. WEDNESDAY Partnership Breakfast and Hot Topics Wednesday begins with the MIBA/ICBA Partnership Breakfast, followed by our popular Hot Topics sessions featuring Mick Campbell, commissioner of the Missouri Division of Finance; Brian Laverdure, senior vice president of digital assets and innovation policy at ICBA; and additional industry experts discussing today’s most important banking issues. REGISTER TODAY Join us at The Lodge of Four Seasons, Lake Ozark, Missouri, for three days of education, networking, entertainment and celebration as we come together for MIBA’s 2026 Community Banking Celebration. Register today at miba.net or call (573) 636-2751. HOTEL RESERVATIONS Room reservations must be made directly with the Lodge. To make online reservations, visit miba.net, click on 2026 Annual Convention, then Hotel. Or call the Lodge direct at (888) 265-5500. Request the MIBA room block and rate of $159, plus tax and $18 resort fee. 20 | The Show-Me Banker Magazine
Thank you 49th ANNUAL CONVENTION & EXPO · 2026 Early Convention Sponsors
Every year, convention season gives community bankers a chance to step away from the day-to-day and think about what’s next. New ideas, industry updates, conversations with peers and the opportunity to reconnect with colleagues from across Missouri make it time well spent. But before packing a suitcase and heading to a convention, it’s worth asking a different question: What conversations should already be happening back at the bank? Having spent more than a decade working inside community banks, and now working alongside them in a different role, I’ve had the opportunity to see banking from two perspectives. One thing that’s become increasingly clear is that many of the challenges banks face today don’t fit neatly into one department. They build gradually, overlap in unexpected ways and often require conversations that extend well beyond a single meeting or committee. Whether it’s staffing, vendor relationships, cybersecurity, succession planning, employee benefits or simply keeping up with the pace of change, management and operations have become more interconnected than ever. Operations Are More Than Processes When people hear “operations,” it’s easy to think about policies, procedures and workflows. Those things certainly matter, but operations are really about helping the bank continue to run well when circumstances inevitably change. Every operational decision has a ripple effect. Hiring a new employee, implementing new technology, selecting a vendor or entering a new market all create opportunities, but they also introduce new considerations. Looking at those decisions through both an operational and risk lens can help reduce surprises later. One pattern I’ve noticed over the years is that the banks that seem to navigate change most smoothly aren’t necessarily the ones with fewer challenges. More often, they’re the ones having thoughtful conversations before those challenges arrive. Risk Doesn’t Stay in One Department One thing I’ve come to acknowledge is that risk has a way of crossing departmental lines. A cybersecurity event quickly becomes an Before the Convention: The Conversations Worth Having By Paige Harper, Risk Advisor, TIG Advisors, MIBA Endorsed Vendor 22 | The Show-Me Banker Magazine
operational issue. An employee departure becomes a succession issue. A vendor disruption becomes a customer service issue. A compliance concern becomes a board discussion. That’s why some of the best operational conversations aren’t really about individual departments at all. They’re about understanding how decisions in one area affect the rest of the organization. Risk management works best when it’s simply part of how a bank operates, not something that’s pulled off the shelf once a year or discussed only at renewal time. People Make the Difference Technology continues to evolve, but community banking has always been, and will continue to be, a relationship business. Across Missouri, banks are balancing recruiting, retention, leadership transitions and preserving institutional knowledge. Those conversations often begin with people, but they affect nearly every part of the organization. Cross-training, succession planning, competitive employee benefits and investing in professional development all contribute to something bigger than good HR practices. They help create continuity, preserve relationships and keep the organization moving forward when change inevitably comes. Community Banks Understand One of the things I’ve always appreciated about community banking is that relationships still matter. Our Missouri banks understand their local markets, local businesses and local economies, from agricultural operations and family-owned businesses to growing communities and urban centers. They know their customers because they’re part of those communities themselves. That creates opportunities to have conversations that go beyond transactions. Whether helping a business owner think through growth, discussing fraud prevention with a retiree or talking with a young family about protecting what they’re building, community banks are uniquely positioned to provide practical guidance that builds confidence and trust. Better-informed customers tend to ask better questions, make more confident decisions and be better prepared when circumstances change. Those outcomes benefit customers, but they also contribute to stronger relationships and healthier banks. Questions Worth Bringing to Convention Convention is a great opportunity to hear new ideas, but it’s also a chance to step back and reflect. As you head into those conversations, it may be worth asking: • Where are we carrying operational risk without realizing it? • If a key employee left tomorrow, what knowledge would leave with them? • Are our vendors making us more efficient — or creating new dependencies? • Have we prepared for the next disruption, or are we still reacting to the last one? • What conversations have we been putting off simply because everyone has been busy? The answers will look different for every institution, and that’s one of the strengths of community banking. There isn’t a one-size-fits-all approach to strong management or sound operations. But the banks that continue asking thoughtful questions, investing in their people and preparing before problems arise are often the ones best positioned for whatever comes next. As Missouri bankers gather this fall, I hope those conversations continue. Not just in convention sessions, but around tables, over coffee and on the drive home. Sometimes the best ideas aren’t the newest ones. They’re the conversations that remind us why thoughtful preparation, strong relationships and a commitment to serving our communities have always been at the heart of community banking. Paige Harper is a risk advisor with TIG Advisors, drawing on more than a decade of experience in community banking. She works with community banks across Missouri, helping them navigate risk management and insurance with a focus on protecting their people, operations and long-term success. 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 • FHA Loans OUR PARTNERS RECEIVE: • Superior Service & Competitive Pricing • No Minimum Volumes • Significant, Non-Interest Fee Income • Non-Solicit Protections & More BANCMAC COMMUNITY BANC MORTGAGE CORP. YOUR COMMUNITY BANK MORTGAGE PARTNER bancmac.com mortgages@bancmac.com 888.821.7729 | NMLS# 571147 The Show-Me Banker Magazine | 23
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