The Missouri Banker September October 2024 : simplebooklet.com

WHY?Lending ServicesOperational ServicesAudit ServicesWe are very fortunate to have Andrew Lee with MIB as a trusted partner in these ever-changing times. MIB has the technology and experience to lead us into the future. The electronic banking site is easy to navigate; and the friendly, knowl-edgeable sta are always there to assist at any time. It is important to feel secure with the people you do business with and MIB has proven that over the numerous years we have done business together. Curt Brumley, President/CEOCommunity Point BankRussellville, MOAndrew LeeCurt Brumley800-347-4MIBmibanc.comMEMBER FDICMortgage Investment Services Corporation22316 Midland Drive • Shawnee, KS • 66226 • 913-390-1010NMLS# 194708 • A Kansas licensed mortgage company #MC 0001182 • Missouri Residential Mortgage Loan Broker License #10-1912 • Oklahoma Mortgage Broker #MB001953 • Colorado License #100044344 • Nebraska Licensed Mortgage Company NMLS#194708 • Arkansas License #124530YEARS24Let’s Talk Fair Lending!Partnering with Mortgage Investment Services Corporation (MISC) means equal access to credit for housing to all within your community. Here’s why collaborating with us sets you apart: • Fair Lending Protocols, Regulatory Compliance • Tailored Solutions for Diverse Clientele • Government nancing options: FHA, VA, & USDA-RD • Rebuilding your community with renovation lending • Expand your customer reachJoin forces with MISC to provide every member of your community with the opportunity for homeownership. We get it right the rst time!Andrew Holtgraves, Senior Vice President • Cell: 913-558-2555Email: Andrew@MISCHomeLoans.com • NMLS: #276932

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ContentsThe Missourifacebook.com/mobankers @mobankers@mobankersMissouri Bankers AssociationFrom our ChairmanCall Out Credit Unions Going Beyond Their Purpose. ........................................ 2From our President and CEOThe Battle Continues on Section 1071 ........................................................ 5American Bankers Association PerspectiveDefend the Dual Banking System ............................................................ 6Department NewsGovernment Relations: Making a Difference With In-District Meetings ............................ 8Legal: Is IRA Good or Bad? Only Time Will Tell ................................................ . 9Compliance: Change is Good, Right? ........................................................ 10MBA VEBA: Pay Less for Health Insurance Out-of-Pocket Costs ................................ 11Next Generation in Banking: Heroes Cup, NextGen Day at the Fed ............................. 12Views from Washington, D.C.MBA Bankers Share Their Views, Concerns on Capitol Hill ....................................... 13Cover StoryTrapped in a Whirlwind .................................... 14Banks call out mounting regulationsGuest CommentaryIncrease Net Interest Income & Win More Deals! ............................................... 18The Death of the Chevron Doctrine: What Next? ............................................. 20Section 1071: What's Next & How to Prepare .................................................. 22Around the StateBeyond Banking: Mark Ramsey .............................................................. 24MBA Events ................................................................................ 26Achievements .............................................................................. 28Jackson Hataway, PublisherLori Bruce, Editor573-636-8151The Missouri Banker (USPS Number 000044, ISSN Number 0893-5637) is published six times a year by the Missouri Bankers Association, 207 E. Capitol Ave., Jefferson City, MO 65101. Second-class postage is paid at Jefferson City, Mo. Copyright© 1998 by the Missouri Bankers Association. All rights reserved. POSTMASTER: Send address changes to The Missouri Banker, P.O. Box 57, Jefferson City, MO 65102. Opinions expressed in any signed article in The Missouri Banker are those of the author and should not be construed as the viewpoint of the editors or of the Missouri Bankers Association. Neither should information provided in The Missouri Banker be construed as legal advice. The Missouri Banker does not provide legal advice, nor does it take the place of legal counsel hired by ﬁnancial institutions. While this publication makes a reasonable effort to establish the integrity of advertisers, it does not endorse advertised products or services, unless otherwise so stated. This issue may contain legislative advertising. Advertising copy is generally segregated from news and other information.Address ChangesSubmit changes for The Missouri Banker to mba@mobankers.com.CONNECT WITH MBA!For the latest news, visit mobankers.com. THE MISSOURI BANKER 1

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Call Out Credit Unions Going Beyond Their PurposeDavid M. Gohn, MBA Chairman West Plains Bank and Trust CompanyAre you ready for some football? The correct answer is always yes! Growing up, I always rooted for the Mizzou Tigers and the Kansas City Chiefs, and I endured many heartbreaks along the way during the 80s and 90s. MU football seasons were lackluster, to put it kindly, and when we thought there was a chance, Lucy yanked away the football once again — 5th down game against Colorado and ﬂea-kicker game against Nebraska. The Chiefs always failed to advance in the playoffs, if they even made it to the post-season.The last few years, it has been a different story. Coming off a Cotton Bowl victory with the potential for MU to be a contender in the new college playoff system and the Chiefs’ quest for a historic third consecutive Super Bowl championship, it’s an exciting time for Missouri football fans.That excitement sours for me, however, when I see credit union logos scattered throughout stadiums. In late August, a Virginia-based credit union signed a multiyear deal for the naming rights to the home stadium of the Washington Commanders. A $17 billion Utah-based credit union purchased the naming rights to Arizona State University’s football stadium for more than $50 million in 2023. And for the Chiefs, there’s a strong credit union presence in Arrowhead. CommunityAmerica Credit Union, Missouri’s largest credit union, is the ofﬁcial checking account for the Chiefs. It also has signed deals with Chiefs quarterback Patrick Mahomes, Kansas City Royals shortstop Bobby Witt Jr. and former St. Louis Cardinals pitcher Adam Wainwright. If the purpose of credit unions is to help those of modest means, how does stadium naming rights and contracts with professional athletes fulﬁll this purpose?These situations are just some of the examples MBA and its members discussed with our Missouri congressional delegation during MBA’s 2024 Washington Visit. Congressman Emanuel Cleaver has been very receptive to our concerns about credit unions playing by different rules than banks, especially concerning the Community Reinvestment Act. During a House Financial Services Committee hearing this summer, Cleaver said, “It is my strong and irreversible belief … that some nonbank entities [should] have CRA requirements in sectors with signiﬁcant public subsidies or support for business activities.” From our Chairman2 mobankers.com

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Call Out Credit Unions Going Beyond Their PurposeMBA’s podcast explores topics relevant and interesting to bankers. Our fun, engaging conversations help you stay ahead of what’s happening in banking. Our Two Cents with MBA is on MBA’s website, iTunes, Apple Podcasts, Google Podcasts and Spotify.The federal tax-exempt status of credit unions also was a main discussion point with my Congressman Jason Smith, chairman of the House Ways and Means Committee. Many tax breaks enacted through the Tax Cuts and Jobs Act of 2017 will soon expire if Congress does not act to extend these. This will increase taxes for citizens, who already pay more in federal taxes than credit unions. Missourians making nearly $60,600 annually pay $11,475 in federal income taxes. Credit unions pay nothing — zero! — in federal income taxes. Credit unions’ federal tax exemption costs the U.S. more than $3.1 billion per year. Is it right and fair for taxpayers to foot the bill for credit unions, especially when they choose to spend hundreds of millions of dollars to have their names on stadiums?For far too long, the mega credit unions have skirted laws and regulations to hold them accountable. If these credit unions want to act and be like banks, then they need to be treated the same as banks and adhere to the same laws and regulations.It is important our lawmakers know if credit unions are truly serving the purpose for which they were originally created. When they go beyond their purpose, then we need to call them out, both in Washington and in Jefferson City. We already know that credit unions intend to ﬁle another bill this next state legislative session to expand their ﬁeld of membership in Missouri. MBA’s government relations team has been coordinating meet-and-greets with area lawmakers so bankers can share what will happen here in Missouri if this bill becomes law. Read Page 8 to learn more about these meet-and-greets and how effective they are to MBA’s advocacy efforts. Also, plan to be a Target Banker for the 2025 state legislative session. The credit union industry will be well-represented in the Missouri Capitol, and we need bankers there to show our strong, united front against the expansion bill.The choice of lawmakers who will determine the fate of credit unions rests with you, Missouri voters. I encourage every Missouri citizen to make their voice heard and vote in the Nov. 5 election. Early voting begins Tuesday, Oct. 22, and runs through Monday, Nov. 4. Polls open at 6 a.m. Tuesday, Nov. 5, and close at 7 p.m. Make a plan to vote, and exercise your right! “For far too long, the mega credit unions have skirted laws and regulations to hold them accountable. If these credit unions want to act and be like banks, then they need to be treated the same as banks and adhere to the same laws and regulations. THE MISSOURI BANKER 3

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The Battle Continues on Section 1071In late August, a U.S. district court judge in Texas dismissed a lawsuit challenging the Consumer Financial Protection Bureau’s ﬁnal rule on Section 1071 of the Dodd Frank Act. The lawsuit was led by Rio Bank, the Texas Bankers Association and the American Bankers Association. This decision falls on the heels of a decision in late June by a U.S. district court in Minnesota to dismiss a lawsuit led by the Minnesota Bankers Association targeting the Federal Deposit Insurance Corporation’s ﬁnancial institutions letter on multiple representment of nonsufﬁcient funds items. Although both rulings are being appealed, they are a disheartening turn of events for our industry and a stark reminder that just because we move our efforts to the courts does not guarantee Jackson Hataway, President and CEO, Missouri Bankers AssociationFrom our President and CEOThe more detailed and proactive we can be when dealing with legislation affecting our industry, the better. We cannot count on the courts to ﬁx errors in statute for us every time.“the courts will rule in our favor — and we haven’t even touched on the CFPB funding mechanism.The battles on multiple court fronts will continue to rage for years. U.S. Supreme Court decisions like the recent decisions to overturn Chevron or limit agency overreach through Major Question Doctrine challenges give us optimism. However, the core commitment we must reach as an industry is to ensure lawmakers construct statute that is clear, concise and bounded.For instance, at the end of Section 1071 in the Dodd Frank Act listing all the statutory data points, there is one ﬁnal bullet, (e) (2) (H), that reads: “any additional data that the Bureau determines would aid in fulﬁlling the purposes of this section.” From that one small seedling in the forest of paper that is the Dodd Frank Act (almost 1,000 pages), the CFPB drew its authority to expand core and supporting data requests to an almost endless extent.It is easy to be critical of allowing that provision to move forward in hindsight. It is more important to realize that even small uncertainties or gaps in statute can have massive implications in the long-term. As you watch the court battles play out — and make no mistake, MBA will be an active supporter of litigation aimed at providing relief to the banking industry in Missouri — keep in mind that the more detailed and proactive we can be when dealing with legislation affecting our industry, the better. We cannot count on the courts to ﬁx errors in statute for us every time. We must work to ensure statute is written that protects consumers and banks and that prevents agencies from bending the will of Congress at their discretion. THE MISSOURI BANKER 5

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Defend the Dual Banking SystemRob Nichols, President and CEO American Bankers AssociationSince the time of President Lincoln, American consumers have beneﬁted from a dual banking system, made up of both state-chartered institutions and federally chartered national banks.This system, which can trace its roots back to the U.S. Constitution, allows consumers to have more choices. It offers them a robust marketplace of banks of different sizes and business models to meet their needs. And it enables the nation’s more than 750 national banks to operate safely, soundly and efﬁciently across multiple jurisdictions under the supervision of the Ofﬁce of the Comptroller of the Currency while at the same time allowing state banks to serve their communities with local supervision. But this system, which has served our country well for more than 150 years, is now coming under threat. Lawmakers in both red states and blue states have ABA Perspectivebegun to pass laws that will interfere with national bank operations, violate federal preemption and tread squarely on the OCC’s turf. Just look at the situation currently unfolding in Illinois, with the Interchange Fee Prohibition Act that was signed into law this summer as part of the state’s budget legislation. This misguided law bans banks, credit unions, payments networks and other entities from charging or receiving interchange fees in Illinois on taxes and tips charged as part of a credit or debit card transaction. This law, which will create unprecedented chaos and confusion for consumers and businesses if allowed to take effect, violates multiple federal statutes, including the National Bank Act and the Federal Credit Union Act. It cannot be enforced against national banks, federal savings institutions or state-chartered banks, as well as federally and state-chartered credit unions. It also runs afoul of the Electronic Fund Transfer Act, which directly addresses the permissible amount of interchange fees for debit card transactions and does not carve out taxes and gratuities. This law, a gift to corporate mega-retailers as part of a last-minute budget deal, is the ﬁrst of its kind to pass in the nation. We can’t let it stand and run the risk other states follow, which is why ABA is ﬁghting back. Together with the Illinois Bankers Association, America’s Credit Unions and the Illinois Credit Union League, we ﬁled a lawsuit challenging the law and are seeking a preliminary injunction pausing implementation until the court can rule on the merits of our case. With top outside lawyers assisting us, we have conﬁdence we will prevail in this case, sending a strong message to other states looking to follow Illinois’ lead.6 mobankers.com

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Get strategies to support your institution’s future and plan for growth at the nation’s premier conference for ag bankers.We’ll look at what’s in store for ag this year and beyond, from Farm Bill reauthorization to articial intelligence and more.REGISTER NOW aba.com/AgConfSAABAAGRICULTURALBANKERSCONFERENCENovember 12–15, 2024Baird Center | Milwaukee, WIWe’ve seen a different kind of challenge to the dual banking system in other states. Florida and Tennessee have put in place their own safety and soundness tests, encroaching on the OCC’s federal overnight of national banks. Like ABA, the OCC has taken notice. We’ve been encouraged by comments from Acting Comptroller Michael Hsu noting that his agency will continue to defend the dual banking system. The acting comptroller pointed out in recent remarks that “increasingly, banks are being asked by states to pick a side in service of performative politics rather than deliberative policy.” This simply shouldn’t be the case, and we will continue to urge the OCC to exercise its authority when states cross the line. Our dual banking system has served Americans well for decades. ABA will continue to push back against efforts to undermine that system, and we’ll keep pressure on regulators to do the same. Email Rob Nichols at rnichols@aba.com. “Lawmakers in both red states and blue states have begun to pass laws that will interfere with national bank operations, violate federal preemption and tread squarely on the OCC’s turf. THE MISSOURI BANKER 7

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Department NewsAn important goal in MBA’s three-year strategic plan is to make every banker an advocate. To help accomplish this, the MBA government relations team is working directly with bankers to host area state lawmakers for informal meetings to discuss issues important to the industry. Leaders of all local banks also are invited to attend.By the end of 2024, we will have hosted four events around Missouri in Cameron, Washington, De Soto and Sikeston. A special thank you to Duane Kohlstaedt from Farmers State Bank, Scott Breckenkamp from First State Community Bank, and Matt Drake from First State Bank & Trust Co. for agreeing to host their local state legislators and fellow bankers. These events have been incredibly fruitful. Much of the discussions have centered on our opposition to credit union ﬁeld of membership expansion, an issue we expect will return in 2025 state legislative session. They also create opportunities to build and strengthen our relationships with lawmakers.As Breckenkamp shared with me after one meeting, “I walked away thinking we made a difference.” He couldn’t have summed it up better.The greatest beneﬁt of in-district meetings is the amount of time and focus that we get from lawmakers. Communicating GOVERNMENTAL RELATIONSMaking a Difference With In-District MeetingsBy Emily Lewis, Vice Presidentwith lawmakers in Jefferson City during the legislative session is critically important. However, the hectic schedule of session limits their time and sometimes forces them to focus on other priorities.At in-district meetings, we have lawmakers’ full attention for a long period of time — upwards of an hour or more. This gives us the opportunity to provide context and background — the “why” — behind our opposition to credit union ﬁeld of membership expansion. It allows us to fully educate lawmakers on credit unions, their unfair competitive advantage and why ﬁeld of membership for large and aggressive credit unions is harmful to their communities and local banks.MBA wants to hold in-district meetings across the state. They have already produced great results with low effort. Please contact the MBA government relations team if you are interested in hosting. We simply ask you to choose a date, location and time, and to encourage other banks to attend. MBA will handle the invitations to lawmakers and provide a program.As we host more of these meetings, the more you will feel that you made a difference. The greatest beneﬁt of in-district meetings is the amount of time and focus that MBA members get from lawmakers. After an August meeting in De Soto with area state lawmakers, Scott Breckenkamp with First State Community Bank said, “I walked away thinking we made a difference.” 8 mobankers.com8 mobankers.com

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Is the Inﬂation Reduction Act good, or is it bad? Recent mixed messages from three federal agencies makes it difﬁcult to tell.The IRA presents signiﬁcant ﬁscal implications for the U.S. concerning green infrastructure. Residential solar panels offer a cautionary tale in the use and pursuit of tax credit incentives for dealers, lenders and homeowners. The U.S. Department of Treasury issued a press release Aug. 7 citing the signiﬁcant home energy cost savings obtained by homeowners under IRA, claiming available credits to make home improvements. (https://home.treasury.gov/news/press-releases/jy2527)“For example, household installing residential solar have saved a median of $2,230 annually, and households that install efﬁcient heat pumps and improve building efﬁciency are expected to save up to $600, $1,200, or $3,100 per year, based on the type of heating and cooling system that is being replaced.” Treasury Secretary Janet Yellen stated in the release that “the Biden-Harris Administration’s top economic priority is lowering costs for American families, and the Inﬂation Reduction Act is advancing that goal by making home energy upgrades more affordable and cutting monthly utility bills.” That same day, Consumer Financial Protection Bureau Director Rohit Chopra warned consumers about fraudulent home solar installation scams “ … to make sure that Americans don’t get burned.” (consumerﬁnance.gov/about-us/newsroom/cfpb-report-ﬁnds-lenders-cramming-markup-fees-and-confusing-terms-into-solar-energy-loans/) The CFPB cited misrepresentations by lenders and solar panel dealers that include hidden mark-up “dealer fees;” misleading claims for federal tax credits, qualiﬁcations to obtain the credits and what consumers will pay; balloon payments tied to expected tax credits; and exaggerated energy savings claims as actual savings can vary signiﬁcantly. On the same day that Yellen was selling the beneﬁts of solar panels, Treasury Deputy Secretary Wally Adeyemo LEGALIs IRA Good or Bad? Only Time Will Tell By Keith Thornburg, Vice President and General Counselannounced a joint undertaking by the CFPB and Federal Trade Commission to address solar panels and “tough stories about Americans being deceived about costs and savings, misled about loans and tax credits, and pressured by aggressive sales and marketing tactics.” (https://home.treasury.gov/news/press-releases/jy2536)In prepared remarks, FTC Chair Lina Khan cited “over a quarter of a billion dollars in solar-related complaints” from January 2022 to June 2024. (ftc.gov/system/ﬁles/ftc_gov/pdf/chair-khan-khan-remarks-cfpb-consumer-solar-fraud-public-brieﬁng.pdf) Khan expressly cited actions against Ygrene, a clean energy ﬁnancing company. Ygrene formerly provided residential Property Assessed Clean Energy ﬁnancing and administration in Missouri. MBA advocated for legislation enacted in 2021 that reformed the state’s PACE law to stop unscrupulous green energy sales and ﬁnancing practices in residential PACE. MBA provided extensive input to the bill, aided by the expertise of its member banks that dealt with the fallout caused by bad dealers and predatory PACE lenders. Another former PACE vendor, Renovate America, that left Missouri ﬁled for bankruptcy in 2020. Two years later, the CFPB proposed new rules in May 2023 to rein in abuses in the PACE program. In announcing the rules, Chopra said, “When unscrupulous companies bait homeowners into unaffordable loans with exaggerated promises of energy bill savings, this can lead to serious ﬁnancial distress.” (consumerﬁnance.gov/about-us/newsroom/cfpb-proposes-new-consumer-protections-for-homeowners-seeking-clean-energy-ﬁnancing/) Before the rules were proposed, MBA submitted a ﬁve-page comment letter to the CFPB in May 2019 in response to the agency’s notice of proposed rulemaking. With the letter, MBA also submitted 22 pages of detailed comments and sample PACE ﬁnancing exhibits.Trillion-dollar programs like the IRA have beneﬁts and costs, and the substantial incentives in these programs can attract bad or incompetent actors. Time will tell if the IRA is good or bad. THE MISSOURI BANKER 9

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Department NewsCOMPLIANCEChange is Good, Right?By Bryan Bradley, CRCM, Vice President of Compliance ServicesIt is no surprise that with rapidly emerging and changing technology, it is sometimes a challenge to stay ahead of the curve and avoid mistakes. Thankfully, the days of computing an annual percentage rate manually are well in the past with the advent of computer programs to perform the heavy lifting, allowing bankers to focus on business development and customer service. However, even the most reliable and well-known systems can cause a noncompliance issue following implementation or a version update. Bankers may want to consider the following information as it relates to systems that assist with the generation of compliance documents, such as deposit and lending disclosures. IMPLEMENTING NEW SYSTEMS When shopping for a new system or considering an upgrade, keep these suggestions in mind.• Compile a list of disclosures, documents or concerns. Designate the items that are most important to the bank so appropriate and relevant questions may be asked during the due diligence process. • Know your vendor and check references. Ask speciﬁc questions of referred parties on any items of concern to gain a comfort level on whether the system can perform as expected. A great place to start is MBA’s VendorPRO website that lists banker contacts for various companies. • Request a demonstration. Ask if a “test” version is available for the bank to navigate and test. • Ensure the vendor provides detailed training on use of the system. Request additional training, when necessary. • If possible, run dual systems for a while to compare results. Identify any glaring differences or potential noncompliance. SYSTEM UPDATESWe hope system updates are executed as intended, but occasionally a designed change may inadvertently affect another part of the program that was not planned. For this reason, it is important to review the system following an update to ensure that the update was installed accurately and did not cause any unintended issues. For example, a vendor might install an update for deposit product disclosures that is intended to simply reformat them. However, a speciﬁc required disclosure item could inadvertently be removed as a result. A recent example concerns Regulation DD required language to describe the balance method used by the bank to impose certain fees that was inadvertently omitted from the disclosure following the update. In such an instance, bank staff should promptly review the appropriate areas within the system and generate “test” accounts and review disclosures to ensure they reﬂect the terms and conditions of the product. Lastly, to the extent possible, keep front line staff informed of upcoming changes and/or issues noted following installation, along with any necessary workarounds to maintain compliance until the system issue has been resolved. This article is for information purposes and does not contain or convey legal advice. The information should not be used or relied upon in regard to any particular situation without consultation with your bank attorney. MBA Compliance Services and its Compliance Force program offer various programs to aid banks with compliance needs. For more information, call 573-636-8151.10 mobankers.com10 mobankers.com

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MBA VEBAPay Less for Health Insurance Out-of-Pocket Costs By Lesley Weaver, Director of Business Development, Insurance ServicesIf you struggle to pay your medical bills, you are not alone. Out-of-pocket health care costs — medical expenses that you pay for yourself as opposed to what your insurance plan pays — can be challenging and stressful. Yearly out-of-pocket health care costs continue to increase for various factors, including technology developments, aging populations, demographic changes, changes in how people use and access health care and price increases for health care-related services. Consider the following to help minimize out-of-pocket costs. • Stay in-network. Save on out-of-pocket costs by using a doctor, hospital or facility that is part of your health plan’s network. A doctor or facility not contracted with your health plan is considered “out-of-network,” which increases your out-of-pocket expenses. • Get preventive care. Routine care such as annual check-ups, immunizations and screenings can help detect or prevent serious diseases, as well as help you stay healthy. Screenings may include annual exams, blood pressure and cholesterol tests, diabetes and colon cancer screenings, and mammograms and Pap tests. Most health plans are required by law to cover eligible preventive care services at 100%. • Save the emergency room for emergencies. Go to the ER for life-threatening conditions and injuries. For colds, fevers, ﬂu symptoms, joint or lower back pain or a broken ﬁnger, an urgent care visit will cost less than an ER visit. Costs for ER care can exceed several hundred or even thousands of dollars, even if you have health insurance. Convenience or express care clinics offer cost-effective medical care for mild illnesses or injuries such as infections, rashes, earaches, minor burns and other routine medical conditions. These care clinics may operate in grocery stores, pharmacies and other retail stores. Virtual care or telehealth is another cost-effective alternative when your physician is not available, it is after hours or the weekend, or you are out of town. Check with your health plan to see if virtual care or telehealth visits are a covered beneﬁt. With virtual care, you can access medical providers and licensed therapists online 24/7 using a phone, tablet or computer. • Know the costs before seeking care. Shop around for the best price for outpatient procedures, MRIs, CTs and other diagnostic testing. Radiology centers, freestanding clinics, outpatient surgery centers and laboratories can give you quality service like a hospital but at a much lower cost. • Explore cost assistance or prescription drug discount programs. Although you may have prescription drug coverage through your employer health care coverage, Medicare or Medicaid, medications expenses can be costly, particularly if you take multiple medications. Good Rx, WellRx or America’s Pharmacy offer discounted pricing for prescriptions. Also consider taking a generic version of a prescription drug. The difference in price between a generic drug and a branded drug can be signiﬁcant. On average, a generic drug will cost about 85% less than its branded equivalent, according to data collected by the U.S. Food and Drug Administration. • Take advantage of ﬂexible spending accounts or health savings accounts. FSAs and HSAs are savings accounts that are useful ways to save money toward health care expenses while allowing you to contribute pre-tax dollars from your paychecks. While structurally similar, FSAs and HSAs differ. There is distinct eligibility, tax, contribution and investing rules that vary between the two. To learn what is best for you, talk to your employer or tax advisor. MBA VEBA offers medical and dental plans, group term life, group long-term and short-term disability and vision beneﬁts to MBA members. MBA VEBA also offers voluntary worksite beneﬁts and pet insurance. If you are interested in learning more about VEBA’s products, contact Lesley Weaver or Tina Woehr at 573-636-8151 or visit mobankers.com. THE MISSOURI BANKER 11

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Next Generation in BankingHEROES CUPMBA’s Next Generation in Banking hosted the 9th Annual Heroes Cup on Monday, Sept. 23, at Highland Springs Country Club in Springﬁeld. Proceeds from this year’s tournament supported the Fort Leonard Wood Mid-Missouri Chapter of AUSA – the Association of the United States Army – and its Warrior in Need Program. The Warrior in Need Program provides immediate relief to enlisted soldiers and their families in critical times of need. Every dollar raised alleviates ﬁnancial burdens for soldiers — 100% of all donations directly supports soldiers and their families.MBA thanks Keith Pritchard, board chairman of Security Bank of Pulaski County in Waynesville, and John Gideon, senior vice president of Heritage Bank of the Ozarks in Lebanon, for highlighting AUSA’s mission. MBA also thanks Jason Whitesell, senior vice president of Mid Missouri Bank in Willard, and Tammy Kelley, vice president/controller and operations ofﬁcer of Branson Bank, for coordinating the Heroes Cup tournament.NEXTGEN DAY AT THE FEDERAL RESERVE BANK OF KANSAS CITYMembers of MBA's Next Generation in Banking enjoyed their time at the Federal Reserve Bank of Kansas City on Wednesday, July 10. Our thanks to President and CEO Jeffrey Schmid for sharing his thoughts about banking and our roles as community bankers.NEXTGEN DAY AT THE FEDERAL RESERVE BANK OF ST. LOUIS Members of MBA's Next Generation in Banking enjoyed their time at the Federal Reserve Bank of St. Louis on Friday, July 19. Our thanks to ofﬁcials with the Federal Reserve for sharing their thoughts about banking and our roles as community bankers.12 mobankers.com

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Views from Washington, D.C.The Missouri banking community was well-represented in Washington, D.C., as 32 bankers from throughout the state attended MBA’s annual Washington Visit from Sept. 16-18. During their time in Washington, MBA members met with Mis-souri’s congressional delegation and individuals with several regulatory agen-cies to share their concerns. In their discussions with lawmakers and their staff members, MBA members highlighted several key areas.• federal tax-exempt status of credit unions and requiring credit unions to adhere to the Community Reinvestment Act, which banks already do• Secure Payments Act• credit interchange fees and Durbin Amendment• Access to Credit for Rural Economy Act, known as the ACRE Act• SAFE Act• deposit insurance reform“Meetings with our congressional delegation were very productive,” said MBA Senior Vice President David Kent. “I want to thank our members who joined us to advocate on behalf of Missouri’s banks and their customers.”MBA members also met with the Federal Reserve, Postal Inspection Service, U.S. Treasury, Consumer Financial Protection Bureau, Federal Deposit Insurance Corporation and Ofﬁce of the Comptroller of the Currency. MBA BANKERS SHARE THEIR VIEWS, CONCERNS ON CAPITOL HILL2024 MBA Washington Visit ParticipantsJim Barnett, Peoples Bank, CubaFrank Berndt, Olsen Palmer LLC, Kansas City, KSScott Breckenkamp, First State Community Bank, WashingtonJ.R. Buckner, First Federal Bank of Kansas CityDan Combs, First State Community Bank, FarmingtonLouis "Buzz" Eckelkamp, Bank of Washington Phil Everitt, Federal Home Loan Bank of Des Moines David M. Gohn, West Plains Bank and Trust Company Molly Hyland, Commerce Bank, St. Louis Mark Jenkins, Bank of BillingsShannon Johnson, UMB Financial Corporation, Kansas CityStephanie Kalahurka, Fenimore Kay Harrison, LLP, Kansas City John Klebba, Legends Bank, Linn Tom Klebba, Legends Bank, LinnPatrick Kussman, Regional Missouri Bank, MarcelineMark Larrabee, Arvest Bank, Kansas CityAndrew Lee, Midwest Independent BankersBank, St. LouisJamie Lipe, First State Community Bank, FarmingtonJenny Michaels, First Federal Bank of Kansas CityBert Purdy, Forvis Mazars, St. LouisDan and Dianna Robb, Jonesburg State BankKyle Smith, Jonesburg State BankDon Thompson, First State Community Bank, Potosi Mark Thompson, Country Club Bank, Kansas CityTerry Thompson, Equity Bank, HigginsvilleRich Weaver, Federal Home Loan Bank of Des Moines Jacob Wilson, Bank of Weston Ted Wilson, Bank of Weston THE MISSOURI BANKER 13

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The discussion was an eye-opener. Tucker Jobes, district director, and Michael Ussery, ﬁeld representative, with Sen. Eric Schmitt’s ofﬁce requested to meet with Branson Bank leadership in late summer. The purpose of their visit — regulatory burdens facing small ﬁnancial institutions.“When I mentioned Section 1071 and Regulation E, they had no idea about the strain these rules place on banks like us,” said Rebecca Mullen, assistant vice president and compliance ofﬁcer for Branson Bank. “It was good to see that they were asking questions about small community banks.”The perspectives on banking regulations that Branson Bank relayed to Schmitt’s staff aren’t unique to that bank. In fact, concerns expressed by bank leadership are ones shared by their peers in Missouri and across the nation.Rules and regulations have always been a constant in the banking industry. However, the ﬁnancial crisis in the late 2000s resulted in Congress passing the Dodd-Frank Act in 2010. That legislation established the Consumer Financial Protection Bureau. Since then, it’s been a whirlwind for the banking community.Jennifer Lawton, vice president – director of compliance for Peoples Savings Bank in Hermann, has a 29-year banking career and has overseen compliance for nearly 15 years. She notes the biggest change she has seen is how the CFPB “has really shaken so much up.”“We are not regulated by the CFPB, but the other banking regulatory agencies tend to follow the CFPB’s lead,” Lawton said. “It creates a lot of havoc because the agencies write rules to regulate the big banks, but it just funnels down to the small community banks.”Lawton expressed that sentiment directly to CFPB Director Rohit Chopra last September during MBA’s 2023 Washington Visit. It was her ﬁrst time participating in MBA’s visit, which includes meetings with Missouri’s congressional delegation and ofﬁcials with federal regulatory agencies. “It was an interesting experience that I found to be very eye-opening,” she said. “I wanted regulators to know what a day looks like at a mid-Missouri community bank as opposed to what they believe when it comes to banking.”That message also was conveyed by Mullen to Schmitt’s staff during the meeting with Branson Bank leadership.“Every day, there is a new rule, an edit to a rule or an update to a rule,” Mullen said, “and some of the rules need an overhaul.”Mullen has spent nine years of her nearly 20-year banking career in compliance. When an agency updates or implements a new rule, it reverberates throughout the bank.“We undergo training to learn about the change or rule and review our existing documentation to update risk assessments, policies, procedures or processes,” Mullen said. “We need to ensure that our core software is correct, and that may require updates. An update or change to a rule requires a lot of time and training, which places additional costs on community banks.”“I wanted regulators to know what a day looks like at a mid-Missouri community bank as opposed to what they believe when it comes to banking. THE MISSOURI BANKER 15

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Mullen cites implementation of Section 1071 of the Dodd-Frank Act as one example requiring signiﬁcant resources. Branson Bank has tasked some of its employees to oversee that the bank has a system in place to track all the data required by Section 1071, including new software for loan processing.“The software can track current information, but it doesn’t help with gathering data from prior years,” Mullen said. “We will have to retrieve that data manually, which will require more time and manpower that takes our staff away from other tasks.”With the complexities of the 1071 rule, Mullen appreciates the work by the Missouri Bankers Association to ﬁght back against the rule and “knowing someone has our backs.”“When we must change or do something a different way, I feel MBA has banks’ best interest at heart,” she said.Banks across Missouri interact daily with MBA Compliance Services, seeking guidance on interpreting rules and asking questions pertaining to activities in their banks. With many years of experience among MBA’s compliance services department, staff knows one thing is certain when it comes to compliance.“There will always be changes in regulations,” said Brent Irwin, CCBCO, MBA assistant vice president for compliance services.“Banking is one of the most regulated industries, and there are tons of laws and regulations that banks must follow,” said Carol Barnett, MBA senior vice president of compliance services. “We are here to help banks make sure they are complying with those laws and regulations.”One aspect in which MBA Compliance Services assists banks is with reviews that generally encompass consumer compliance regulations. Staff also provides tailored reviews on a speciﬁc area, such as TRID (TILA-RESPA Integrated Disclosure) reviews. Review services include compliance reviews, Bank Secrecy Act reviews, HMDA (Home Mortgage Disclosure Act) reviews, fair lending reviews and off-site advertising reviews.Bryan Bradley, CRMC, MBA vice president of compliance services, has a speciﬁc detail in mind when conducting bank reviews. “I'm looking for things like consumer harm that I don’t want to ﬁnd in a bank’s procedures,” he said. “That is always in the back of my brain when I'm doing a review.”Bradley’s concentration on “one off little anomaly” in reviews stems from the actions of the CFPB during the past several years. As one example, he cites the agency’s focus on overdraft fees. Bradley said banks must adhere to certain parameters within the account setup and the servicing of that account. “If a bank doesn’t follow that to the tee, it could impose a fee where a customer didn’t opt into it or maybe the customer opted in and opted out, and now a fee subsequently happened,” Bradley said. He added that reviews dig deeper into a bank’s process for overdraft services in asking more questions. “Asking questions helps avoid consumer harm,” said Bradley, who noted that reviews help prepare banks for their examinations by regulators. “Banks with the most successful compliance programs will ensure that their policies and procedures, especially procedures, reﬂect exactly how the bank employees should handle transactions and customer interactions while meeting regulatory expectations,” said Gina Jolly, CRCM, MBA vice president of compliance services. “Procedures should be reviewed and updated frequently to ensure they match your bank’s operations.”16 mobankers.com

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The onslaught of regulations in recent years has demonstrated the need for compliance teams to be involved with discussions with board members and executives. “The need for training and resources to comply with new regulations isn’t slowing down, and compliance ofﬁcers need support and resources to adhere to these changes,” Barnett said. “Doing so protects your customers, your staff and your bank.” Irwin added that compliance ofﬁcers’ engagement with bank leadership “will greatly increase the likelihood a compliance ofﬁcer can adjust or create new paths forward when changes are needed.”Those new paths include advocacy for compliance staff. As compliance ofﬁcers, both Lawton and Mullen never considered that they would need to interact with lawmakers. Now, they ﬁnd advocacy is a constant in their banking roles.“Be a voice where you can be,” Lawton said. “Find opportunities to be an advocate. Have conversations with your senators, representatives and regulators. You can learn a lot by just talking with one another.” “The need for training and resources to comply with new regulations isn’t slow-ing down, and compliance ofﬁcers need support and resources to adhere to these changes.MBA COMPLIANCE BENEFITS MBA offers several free services for member banks’ compliance needs.Compliance Hotline — guidance on federal and state banking laws and regulations MBA Compliance Update — e-newsletter overing hot topics and important regulatory developmentsThe Missouri Banker — in-depth commentaries on speciﬁc compliance topicsComment Letters — MBA prepares comment letters on proposed compliance-related regulationsRegional Peer Groups — interact with peers to share and discuss compliance issues affecting the ﬁnancial industryCompliance Committee — assist in planning MBA Compliance Conference and providing input on other compliance servicesMember banks can take advantage of these MBA compliance services.Education — various compliance trainingopportunities through schools, workshops, conferences, seminars and webinars; customized bank training for employees and boardsConsulting — customized consulting to help new compliance ofﬁcers, provide policy/procedures consulting on a speciﬁc topic, assist with exam follow-up projects, etc.Reviews — consumer compliance reviews,Bank Secrecy Act reviews, HMDA reviews, fair lending reviews and off-site advertising reviewsPublications — books and manuals offered by MBA covering various compliance topics, from titling deposit accounts to handling garnishments and levies, to a summary of state banking legislation THE MISSOURI BANKER 17

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Submitted by StrunkIncrease Net Interest Income & Win More Deals! Guest CommentaryWhen pricing commercial loans, many bankers “look down the street” to see what the competition is doing. Ironically, those bankers are looking at your bank to see what rate to offer! What if neither bank knows how to ensure the loan or the borrower’s relationship is proﬁtable?Large and regional banks used pricing tools in the mid-2000s to win more deals and ensure the loan/relationship met proﬁtability targets. Community bankers were left out because of the complexity and cost of the pricing solutions.Then from late 2008 until March 2022, rates were so low that almost any loan a bank could make to a credit-worthy borrower was better than investing in Fed funds. However, rates have risen dramatically in the past two years while liquidity has diminished to a great degree. Once again, precision in loan pricing has become a major consideration.Now is the time to give loan ofﬁcers the tools they need to win more deals while meeting proﬁtability goals. Just like loans, size also matters when it comes to deposits. Let’s look at several of these considerations.COMPETITIONPricing commercial loans can be daunting, especially in areas where competition is ﬁerce. Often, banks have a customer — particularly when the customer is one of its most credit-worthy customers — who indicates they can get a better deal from another bank. Does your bank blindly match the rate, or do you let the customer take the competitor’s deal? The largest loan opportunities drive your net interest income — you can’t afford to leave winning or losing to chance.SIZE Creditworthiness of the borrower, term of the loan and size of the loan are the three main factors that drive loan proﬁtability. Most ﬁnancial institutions focus on the ﬁrst two factors but ignore the third. Worse, the third is often the driver that results in the biggest rate differentiation.Small dollar loans are not nearly as proﬁtable as larger loans because the costs associated with underwriting and servicing must be considered. Even when varying the costs based on size of loan, this dynamic is still true. The smaller dollar loans simply don’t produce enough dollars of net interest income to cover even the most modest operating costs.Does that mean banks always have to price up smaller loans to achieve or proﬁt targets? Of course not; not if you have a customer relationship that is proﬁtable enough to carry the smaller loan. However, it then becomes critical to have an easy way for lenders to have customer proﬁtability data at their ﬁngertips.OVERPRICING AND UNDERPRICINGMost banks overprice their largest, most valuable customers and underprice their smaller, least proﬁtable customers. This is a troubling prospect because banks give the best deal to those who contribute the least to their bottom line while running the risk of losing their most proﬁtable relationships.Banks must have a way to set proﬁtability targets that are applied consistently to every pricing decision. The key is consistency and discipline. Banks want to be consistent from lender to lender, customer to customer and, most 18 mobankers.com

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importantly, from one point in time to another as the interest rate environment changes. HOW DOES A PRICING TOOL HELP MY BANK?An empirically based pricing solution offers lenders the ability to vary rate, fee, risk premium and term structure, among other variables, to understand the drivers of proﬁtability and develop pricing options for borrowers that achieve the bank’s target proﬁtability objectives. It is critical to apply consistent assumptions for loan origination, loan servicing and cost of funds so that all pricing decisions are considered based on a level playing ﬁeld. An effective pricing solution should provide:• lenders with the tools needed in an increasingly competitive environment• a relationship proﬁtability module so relationship value can be factored into the decision• instant adjustments in a changing rate environment to ensure pricing consistency• rate sheets for consumer loans and interest-bearing deposit products• pricing options that win more dealsA more disciplined and consistent pricing methodology will increase your bank’s net interest income by at least 25-50 basis points. With increasing margin pressure in 2024, now is the time to consider adjusting your pricing practices. For the past 30 years, Strunk has helped more than 1,800 community ﬁnancial institutions increase income with a variety of innovative products and services. Contact Mike Sobba at msobba@strunklp.com or 816-225-8793 to learn more, or visit strunklp.com. Strunk is an MBA endorsed partner. ✓ Arm Lenders with Tools They Need ✓ Calculate Relationship Protability ✓ React to Changing Environment ✓ Drive Pricing Consistency ✓ Improve Net Interest Margin ✓ Give Clients Options ✓ Win More DealsPRICING MANAGERPRICING MANAGERPricing Manager is a fully hosted, web based solution that allows banks to deploy a tool to all lenders so that they are equipped to price loans protably based on the bank’s target protability objectives.INCREASE NIM & WIN MORE DEALSINCREASE NIM & WIN MORE DEALSwww.strunkaccess.com | info@strunkaccess.com | 800.728.3116 THE MISSOURI BANKER 19

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Submitted By Lathrop GPMThe last week of June was monumental for those subject to regulation by federal administrative agencies. Over the course of 24 hours, the U.S. Supreme Court issued two rulings that have extensive implications for administrative agency power to issue rules and initiate enforcement actions.In Jarkesy v. Securities and Exchange Commission, the Supreme Court held that regulated persons and entities charged by the SEC with alleged fraud subject to civil penalties have a constitutional right to a jury trial pursuant to the Seventh Amendment. In recent years, the SEC has increasingly used its internal administrative proceedings (which are adjudicated before SEC-appointed administrative law judges) to pursue its aggressive enforcement policies. The ruling in Jarkesy certainly throws a wrench into those efforts and likely will result in many more SEC enforcement actions being ﬁled in federal courts.On the heels of that decision, just one day after the Jarkesy opinion, the Supreme Court drove a stake into the heart of the Chevron doctrine, which had mandated judicial deference to federal administrative agency actions and policy decisions. In Loper Bright Enterprises v. Raimondo, the Supreme Court ruled that statutory ambiguities do not constitute implicit delegations of authority to agencies by Congress. This decision reverses the Supreme Court’s seminal 1984 decision in Chevron USA Inc. v. The Natural Resources Defense Council Inc., a decision followed by and adhered to by courts and relied upon by federal agencies for the past 40 years. In Loper Bright Enterprises, the court left the question in no doubt: “Chevron is overruled. Courts must exercise their independent judgment in deciding whether an agency has acted within its statutory authority, as the APA requires.”Essentially, the Supreme Court simply reimposed and emphasized the requirement of judicial oversight of administrative agencies as required by the Administrative Procedure Act. But the shockwaves from these decisions will resonate for years.Guest CommentaryThe Death of the Chevron Doctrine: What Next?20 mobankers.com

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Viewed together, these two decisions signal a sea change for the administrative state virtually overnight. One can expect additional challenges to agency actions and rulemaking. In addition, more than 20 federal agencies that have internal administrative law courts similar to the SEC’s ALJ framework may well face judicial challenges modeled on Jarkesy.FUTURE IMPLICATIONSThese two actions have ushered in a new era of judicial scrutiny over administrative actions. We anticipate that going forward, more parties aggrieved by overbroad, arbitrary and capricious administrative rules, regulations and enforcement actions aggressively will pursue judicial challenges. The key takeaway is that there has never been a better time in four decades to challenge a potentially overbroad or otherwise invalid federal agency action. Although any judicial challenge against a federal agency can be time consuming and expensive, that investment of effort and treasure makes more sense now than at any time in recent memory. And importantly, the Supreme Court is not done with its overhaul of the administrative state as there are other cases working their way through the judicial system that likely will further deﬁne this new post-Chevron era. Lathrop GPM provides a full spectrum of corporate legal services: business transactions, employment and employee beneﬁts, environmental, intellectual property and litigation. In addition, we offer a large and sophisticated wealth strategies team, which advises businesses, families and individuals.Lathrop GPM provides the comprehensive array of services required by ﬁnancial institutions and related entities. Our lawyers function as a cohesive team to provide quality legal services in a cost-effective manner across the full spectrum of legal issues.Our attorneys maintain deep professional and personal relationships with key ﬁnancial institutions. Over the decades, the ﬁrm and our attorneys have continually stayed on the cutting edge of developments affecting ﬁnancial institutions, including loan documentation, loan enforcement, loan workout and bankruptcy matters, tax exempt ﬁnance, ﬁduciary, trust and pension issues, employment and labor relations, environmental law, federal and state regulatory law and all areas of related litigation. Learn more at lathropgpm.com. Lathrop GPM is an MBA associate member. BANCMACCOMMUNITY BANC MORTGAGE CORP.YOUR COMMUNITY BANK MORTGAGE PARTNERbancmac.commortgages@bancmac.com888.821.7729|NMLS# 571147BancMac 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 LoansOUR PARTNERS RECEIVE:• Superior Service & Competitive Pricing• No Minimum Volumes• Signiﬁcant, Non-Interest Fee Income• Non-Solicit Protections & MoreOutsourced Banking Solutions was formed in 2020 with the mission to bring high quality loan review and credit risk services to community nancial institutions. OBS brings high quality, experienced, local credit professionals who fully understand how loan production, loan administration, credit risk management, and regulatory compliance systems work together most eectively. Our team are experts in these areas, having served in capacities such as senior lenders and chief credit ocers in community banks. OBS is aordable and currently serving banks throughout the state of Missouri. For additional information, please check out our website at outsourcedbankingsolutions.com or contact Steve at Steve.middelkamp@outsourcedbankingsolutions.com. Steve MiddelkampDirector of Business DevelopmentQuade WoodPrincipalTerry VisinneDirector of Loan Review THE MISSOURI BANKER 21

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By Brad Stumpe, CPA, CRCM Guest CommentaryThe landscape of small business lending is evolving with the recent developments surrounding Section 1071 of the Dodd-Frank Act. Following the Consumer Financial Protection Bureau’s issuance of a ﬁnal rule and subsequent legal challenges, the U.S. Supreme Court’s ruling in favor of the CFPB has set new compliance deadlines. These changes are crucial for your institution, whether you’re in Tier 1, 2 or 3, affecting when and how you collect and report data on small business loans. Understanding these requirements, preparing your team and adjusting your processes will be essential to navigate this new regulatory environment effectively. WHAT’S NEXT FOR SECTION 1071?After the CFPB issued a ﬁnal rule implementing Section 1071 of the Dodd-Frank Act, legal challenges were ﬁled leading to a stay pending the Supreme Court decision in CFPB v. CFSA. In June 2024, following a ruling in favor of the CFPB, compliance deadlines were extended as follows.• Tier 1 — 2,500 or more originations to small businesses in each of the last two years• new compliance date: July 18, 2025• ﬁrst ﬁling deadline: June 1, 2026• Tier 2 — 500 or more originations to small businesses in each of the last two years• new compliance date: Jan. 16, 2026• ﬁrst ﬁling deadline: June 1, 2027• Tier 3 — 100 or more originations to small businesses in each of the last two years• new compliance date: Oct. 18, 2026• ﬁrst ﬁling deadline: June 1, 2027A small business, including farms, is one with gross annual revenues of $5 million or less during its preceding ﬁscal year. Section 1071 requires lenders to collect certain information including, but not limited to, the following.• Application-Related Data• application date, method, recipient • type of credit and guarantees • credit purpose, action taken/date and denial reasons• amount applied for and approved/originatedSECTION 1071: WHAT'S NEXT & HOW TO PREPARE22 mobankers.com

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• Applicant-Related Information• gross annual revenues• NAICS code• number of workers• time in business• census tract• ownership status (minority-, women- or LGBTQI+-owned)• ethnicity, race and sex of owners• Pricing-Related Information• interest rate• index name/value, margin and initial rate period• origination charges• broker fees• annual charges• prepayment penaltyAlthough the Dodd-Frank Act required a portion of this information, many of the data ﬁelds, particularly pricing data, were added at the CFPB’s discretion. One potential outcome of the legal challenges is a reduction in data ﬁelds.HOW TO PREPAREData CollectionDiscuss how to collect, assemble and report the information. Involve staff from all lending lines and every step in the process. Include someone involved in HMDA reporting.Because the regulation requires procedures that are reasonably designed to collect this information for all applications, including those that do not result in origination, the request should be made early in the process.In recent Anders webinars, more than 50% of participants reported they had either historically used or recently implemented a commercial loan application, another third planned to institute one and only about 10% planned to continue without one.Rules surrounding how ethnicity, race and sex are collected under HMDA and 1071 are different. Front line staff or electronic systems that collect this data must quickly discern whether the application is subject to HMDA or 1071 so the correct information is properly collected.Public DataJust like with HMDA, 1071 data will be public. What will it say about your application/loan distribution, denial rates and pricing practices in communities with various demographic characteristics, to businesses with owners having various demographic characteristics and to businesses with a certain ownership status? Consider whether you want to make changes to your underwriting and pricing processes. Section 1071 data won’t tell the whole story, but it will be the only part of the story available to the public.FirewallThis provision says that someone involved in making any determination on an application, either to originate the loan or set the terms, should not have access to ethnicity, race, sex and ownership information. Although the feasibility exception states that stafﬁng and procedures do not need to be changed to meet this rule, the feasibility of erecting a ﬁrewall must be evaluated on a case-by-case (position-by-position) basis. Taking ActionDetermine who in your organization will be responsible for 1071 and ensure they have the needed time and resources. Become involved with peer groups to broaden your perspective and learn about the approach of others to comply with 1071. As an audit partner for Anders, Brad Stumpe, CPA, CRCM, leads the team on regulatory compliance. Stumpe works with banks to help them navigate and comply with evolving regulatory compliance issues. Through a collaborative approach and a combination of tax, audit and advisory services, Anders' team of CPAs and banking advisors offer the industry insights and ﬁnancial expertise needed to grow. Anders works with ﬁnancial institutions to navigate HMDA, CRA and other complex compliance requirements and evolving regulations so they can do what they do best: helping clients reach their goals. Learn more at anderscpa.com. Anders is an MBA associate member.The Anders Banking and Financial Institutions Team closely follows compliance news to help guide and prepare banks for upcoming compliance changes. Scan the QR code to receive invites to free quarterly webinars and other ﬁnancial insights for the banking industry. THE MISSOURI BANKER 23

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Around the StateYou may not know Mark Ramsey. However, you may recognize his photography, especially if you have a Scenes of Missouri calendar from the Missouri Bankers Association. Ramsey, president of County Bank in Brunswick, has had a photo featured in MBA’s calendar 16 times since 2009. The 2025 calendar marks his last photo for the calendar as Ramsey, who is celebrating 45 years in banking this October, will retire from banking later this year to pursue his passion — wildlife photography.His love of photography stems from his grandfather, who took thousands of pictures and made them into slides. “As a kid, I bugged grandpa for picture shows,” Ramsey laughs.Ramsey enjoyed photography, but it was expensive to purchase ﬁlm and then develop photos. The dawn of the digital camera in the early 2000s changed the game. Ramsey could take hundreds of photos, and he was hooked!20102020202020212023A hunter, Ramsey enjoys being outdoors. He always packs his camera on his hunting excursions, ready to capture the perfect shot of nature’s beauty in the wild. In fact, Ramsey never goes anywhere without his cameras.“Friends and family always let me know if there’s something I need to shoot,” Ramsey said, “so I’m ready to go whenever I get a call or text.”As Ramsey’s passion for wildlife photography developed, he began submitting his photographs to various contests and calendar publications. This included MBA’s Scenes of Missouri calendar. He vividly recalls capturing two of his favorite photos for the calendar from his farm.Beyond Banking: Mark Ramsey, President County Bank, Brunswick2011“I was sitting in the blind on my farm watching the deer eat when a cardinal began feeding in the same area,” Ramsey said. “I hoped and patiently waited for the cardinal to move closer so I could get the shot in the camera’s frame. Once the cardinal moved into the frame, I was smashing the shutter to get as many shots as possible.”Mark's Favorite MBA Calendar PhotosBy Lori Bruce, Director of Communications24 mobankers.com

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That photo graced MBA’s 2023 calendar. Ramsey also had another encounter with deer eating on the farm, but with a different creature this time.“We had six inches of snow overnight, and I wanted to get shots of the deer feeding in the beans. I trudged down in the snow to my blind and get out my camera to only to discover that the battery was still in the charger inside my house,” Ramsey said.He trudged back up to the house and returned to the blind, waiting for the perfect shot.“After a while, the deer started popping their heads up. I thought my wife was making noise near the house and was nervous she would run off the deer,” Ramsey said. “At that moment, a coyote walked into the frame and I thought, ‘Don’t mess this up.’”That moment was absolute silence in the blind, except for the soft click of the camera’s shutter going off as Ramsey took around 400 photos of the coyote with the deer. That photo graced MBA’s 2011 calendar, as well as one for Orscheln Farm and Home. Ramsey takes pride that his photographs are straight from his camera; he does not use Photoshop or other software to alter his photos. He has lost track of the number of photos he’s taken over the years. Ramsey is now on his fourth camera and also uses his phone camera. “You can take nice pictures of sunrises and sunsets with a good camera phone,” he said.202520122014201620172019201620222021202420202019As his retirement nears, Ramsey credits his 45-year banking career to great co-workers. He also feels one of his greatest career accomplishments is “running a solid bank.” Retirement, however, brings more time and opportunities for Ramsey to pursue photography even further.“With photography, hunting season never ends because you’re always still hunting for that perfect shot,” he said. Share your Beyond Banking ideas to Lori Bruce, MBA communications director, at mba@mobankers.comfor posssible inclusion in The Missouri Banker.Submit Your Story! THE MISSOURI BANKER 25

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13. Publication Title 14. Issue Date for Circulation Data BelowMBA BANKERS SERVICE CORPORATION, INC./MISSOURIBANKER (THE)07/01/202415. Extend and Nature of CirculationAverage No. Copies Each IssueDuring Preceding 12 MonthsNo. Copies of Single IssuePublished Nearest to Filing Datea. Total Numbers of Copies (Net press run)1634 1500b. PaidCirculation(By MailandOutsidethe Mail)(1)Mailed Outside County Paid Subscriptions Stated on PSForm 3541(include paid distribution above nominal rate,advertiser's proof copies, and exchange copies)(2)Mailed In-County Paid Subscriptions Stated on PS Form3541(include paid distribution above nominal rate,advertiser's proof copies, and exchange copies)(3)Paid Distribution Outside the Mails Including SalesThrough Dealers and Carriers, Street Vendors, CounterSales, and Other Paid Distribution Outside USPS(4)Paid Distribution by Other Classes of Mail Through theUSPS (e.g. First-Class Mail)1364 128450 480 020 42c. Total Paid Distribution (Sum of 15b (1), (2), (3), (4))1434 1374d. Free orNominalRateDistribution(By MailandOutside theMail)(1)Free or Nominal Rate Outside County Copiesincluded on PS Form 3541(2)Free or Nominal Rate In-County Copies included onPS Form 3541(3)Free or Nominal Rate Copies Mailed at Other ClassesThrough the USPS (e.g. First-Class Mail)(4)Free or Nominal Rate Distribution Outside the Mail(Carriers or other means)0 00 00 020 42e. Total Free or Nominal Rate Distribution (Sum of 15d (1), (2), (3), (4))f. Total Distribution (Sum of 15c and 15e)g. Copies not Distributedh. Total (Sum of 15f and 15g)i. Percent Paid ((15c / 15f) times 100)20 421454 14160 01454 141698.62 % 97.03 %16.If total circulation includes electronic copies, report that circulation onlines below.a. Paid Electronic Copiesb. Total Paid Print Copies(Line 15C) + Paid Electronic Copiesc. Total Print Distribution(Line 15F) + Paid Electronic Copiesd. Percent Paid(Both Print and Electronic Copies)0 00 00 00.00 % 0.00 % I Certify that 50% of all my distributed copies (Electronic and Print) are paid above a nominal price.17. Publication of Statement of Ownership13. Publication Title 14. Issue Date for Circulation Data BelowMBA BANKERS SERVICE CORPORATION, INC./MISSOURIBANKER (THE)07/01/202415. Extend and Nature of CirculationAverage No. Copies Each IssueDuring Preceding 12 MonthsNo. Copies of Single IssuePublished Nearest to Filing Datea. Total Numbers of Copies (Net press run)1634 1500b. PaidCirculation(By MailandOutsidethe Mail)(1)Mailed Outside County Paid Subscriptions Stated on PSForm 3541(include paid distribution above nominal rate,advertiser's proof copies, and exchange copies)(2)Mailed In-County Paid Subscriptions Stated on PS Form3541(include paid distribution above nominal rate,advertiser's proof copies, and exchange copies)(3)Paid Distribution Outside the Mails Including SalesThrough Dealers and Carriers, Street Vendors, CounterSales, and Other Paid Distribution Outside USPS(4)Paid Distribution by Other Classes of Mail Through theUSPS (e.g. First-Class Mail)1364 128450 480 020 42c. Total Paid Distribution (Sum of 15b (1), (2), (3), (4))1434 1374d. Free orNominalRateDistribution(By MailandOutside theMail)(1)Free or Nominal Rate Outside County Copiesincluded on PS Form 3541(2)Free or Nominal Rate In-County Copies included onPS Form 3541(3)Free or Nominal Rate Copies Mailed at Other ClassesThrough the USPS (e.g. First-Class Mail)(4)Free or Nominal Rate Distribution Outside the Mail(Carriers or other means)0 00 00 020 42e. Total Free or Nominal Rate Distribution (Sum of 15d (1), (2), (3), (4))f. Total Distribution (Sum of 15c and 15e)g. Copies not Distributedh. Total (Sum of 15f and 15g)i. Percent Paid ((15c / 15f) times 100)20 421454 14160 01454 141698.62 % 97.03 %16.If total circulation includes electronic copies, report that circulation onlines below.a. Paid Electronic Copiesb. Total Paid Print Copies(Line 15C) + Paid Electronic Copiesc. Total Print Distribution(Line 15F) + Paid Electronic Copiesd. Percent Paid(Both Print and Electronic Copies)0 00 00 00.00 % 0.00 % I Certify that 50% of all my distributed copies (Electronic and Print) are paid above a nominal price.17. Publication of Statement of OwnershipPS Form 3526Statement of Ownership, Management, and Circulation(All Periodicals Publications Except Requester Publications)1. Publication Title 2. Publication Number ISSN 3. Filing DateMBA BANKERS SERVICE CORPORATION, INC./MISSOURI BANKER (THE)44 15203298 09/30/20244. Issue Frequency 5. Number of Issues Published Annually 6. Annual Subscription PriceBIMONTHLY 6 $ 0.007. Complete Mailing Address of Known Office of PublicationPO BOX 57JEFFERSON CITY, NA, MO 65102-0057Contact PersonMO BANKERS ASSOCTelephone(573) 636-81518. Complete Mailing Address of Headquarters or General Business Office of PublisherPO BOX 57JEFFERSON CITY, MO 65102-00579. Full Names and Complete Mailing Addresses of Publisher, Editor, and Managing EditorPublisher (Name and complete mailing address)JACKSON HATAWAYPO BOX 57JEFFERSON CITY, MO 65102-0057Editor (Name and complete mailing address)LORI BRUCEPO BOX 57JEFFERSON CITY, MO 65102-0057Managing Editor (Name and complete mailing address)LORI BRUCEPO BOX 57JEFFERSON CITY, MO 65102-005710.Owner (Do not leave blank. If the publication is owned by a corporation, give the name and address of the corporation immediately followed bythe names and addresses of all stockholders owning or holding 1 percent or more of the total amount of stock. If not owned by a corporation, givenames and addresses of the individual owners. If owned by a partnership or other unincorporated firm, give its name and address as well asthose of each individual owner. If the publication is published by a nonprofit organization, give its name and address.)Full Name Complete Mailing AddressMISSOURI BANKERS ASSOCIATION PO BOX 57, JEFFERSON CITY, MO 65102-005711.Known Bondholders, Mortgagees, and Other Security Holders Owning orHoding 1 Percent or More of Total Amount of Bonds. Mortgages, or OtherSecurities. If none, check boxXNoneFull Name Complete Mailing AddressPS Form 3526, September 2007 (Page 1) PRIVACY NOTICE: See our privacy policy on www.usps.comX If the publication is a general publication, publication of this statement is required. Will be printed Publication not required.in the 10/01/2024 issue of this publication.18. Signature and Title of Editor, Publisher, Business Manager, or Owner Title DateLori Bruce Communications Director 09/30/2024 12:00:52 PMI certify that all information furnished on this form is true and complete. I understand that anyone who furnishes false or misleading information onthis form or who omits material or information requested on the form may be subject to criminal sanctions (including fines and imprisonment) and/orcivil sanctions (including civil penalties).PS Form 3526, September 2007 (Page 2) PRIVACY NOTICE: See our privacy policy on www.usps.com2024 BSA/AML AND COMPLIANCE CONFERENCESSTATEMENT OF OWNERSHIP FOR THE MISSOURI BANKERThe U.S. Postal Service requires publishers of publications, which are qualiﬁed for periodicals mail, to ﬁle the annual Statement of Ownership, Management and Circulation Form and publish the completed form in its periodical. THE MISSOURI BANKER 27

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AchievementsBranson Bank promoted Rebecca Mullen to assistant vice president. As the bank’s compliance ofﬁcer, Mullen oversees the Compliance Department and ensures banking regulations are monitored, followed and communicated. A certiﬁed fraud professional, she oversees fraud concerns and provides educational tools for associates, customers and the community, while supporting individuals who have fallen victim to scams. She is responsible for all bank regulation and holds the titles of BSA, USA Patriot Act and OFAC Ofﬁcer. Mullen joined the bank in 2013 and transitioned to the compliance department in 2015. PJ Thompson has assumed the role of chief operations ofﬁcer at Country Club Bank in Kansas City. He continues to serve as chief ﬁnancial ofﬁcer, a role he has held since December 2022. A third-generation banker, Thompson joined the bank in January 2020 as vice president of corporate and ﬁnancial administration. Guaranty Bank in Springﬁeld welcomed new employees. Lisa McGhee was named treasury management sales ofﬁcer. She has more than 18 years of experience in ﬁnancial services. Erik Dahlgren joins the bank’s the consumer lending team as assistant vice president, consumer lender and underwriter. He has six years of banking experience.Hawthorn Bank in Lee’s Summit welcomed two new employees. Stacy Meoli was named senior vice president, director of operations. Meoli oversees deposit and digital banking functions, including training and customer service. She brings a wealth of expertise to the ﬁnancial services industry with experience in banking, investments and ﬁntech. Greg Singleton was named senior vice president, commercial banker. He brings extensive knowledge and more than 30 years of experience in commercial banking that includes commercial lending, lines of credit, cash management and deposit services. Around the StateRebecca MullenSend achievements, news and announcements to Lori Bruce, MBA communications director, at mba@mobankers.comfor posssible inclusion in The Missouri Banker.Submit Your News! PJ ThompsonFCNB Bank, headquartered in Steelville, announced several staff promotions. Tommy Murphy was promoted to vice president, information technology ofﬁcer at Steelville. Murphy joined the bank in 2019 and has more than 23 years of experience in the ﬁnancial and retail services industries. Shannon Caron was promoted to assistant vice president at Cuba. Caron joined the bank in 2019 and currently serves as an elite banking manager and marketing coordinator for the Cuba market. Paige Ceja was promoted to assistant vice president at Rolla. Ceja, an elite banking manager, has eight years of ﬁnancial experience and joined the bank in 2020. Kelly Hohe was promoted to assistant vice president, branch and community relations ofﬁcer at Rolla. Hohe has been with the bank since 2019 and has more than 18 years of experience in the ﬁnancial, retail and sales industries. Shannon Reed, loan ofﬁcer, was promoted to assistant vice president at Rolla. With a career spanning 27 years in the ﬁnancial and food services industries, Reed has been with the bank since 2022. Troy Suermann, assistant branch manager, was promoted to assistant vice president, collections representative at Eureka. Suermann has previous experience in customer service and retail sales, joining the bank in 2019. Will Swindell was promoted to assistant vice president at Eureka. Swindell has nine years of management and customer service experience and has been with the bank since 2023. He currently serves as an elite banking manager. Tommy Murphy Shannon CaronPaige Ceja Kelly HoheShannon Reed Troy SuermannStacy Meoli Greg SingletonLisa McGhee Erik DahlgrenWill Swindell28 mobankers.com

The Missouri Banker September October 2024

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