A publication for members of the North Dakota Bankers Association - December 17, 2020 Volume 20 Issue 12
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A publication for members of the North Dakota Bankers Association.
1 Volume 20 • Issue 12 December 17, 2020
Jolene German Dorothy Lick Lisa Dolajak
Administrative Assistant SVP of Education Communications & Marketing Coordinator
Rick Clayburgh Jackie Bauer Angi Day
President & CEO Business & Database Coordinator Benefits Coordinator
Ann Reich
SVP of Strategic Partnerships
NDBA • PO Box 1438, Bismarck, ND 58502-1438 • Ph: 701.223.5303 • Fax: 701.258.0218 • Email: ndba@ndba.com • www.ndba.com
CHaiRMaN’S CORNER
Happy Holidays Everyone!
I always think of this season as a time of hope and a time to look forward to the
next year. There is the promise that with vaccines, we may get back to life as we
Jolene Muscha knew it before the pandemic. And while that may be a few months away, we
NDBA Chairman can still plan and anticipate things... like the chance to spend time with family
President
The Union Bank and friends again without a sense of fear.
of Glen Ullin
As bankers, we always strive for a better future, even if it is only the next year we
are thinking about. So I say, get out the ice skates and the hot chocolate (with or
without schnapps) and make that plan for 2021 – it can happen!
I wish you a season of health and happiness and a new year of hope and
positivity!
Upcoming NDBA Events
JANUARY 2021 FEBRUARY 2021 MARCH 2021 February 2021
S M T W T F S S M T W T F S S M T W T F S 16 & 23 UCC Article 9 Virtual Seminar
1 2 1 2 3 4 5 6 1 2 3 4 5 6
March 2021
3 4 5 6 7 8 9 7 8 9 10 11 12 13 7 8 9 10 11 12 13 15-17 ABA Washington Summit -
Washington Marriott Marquis
10 11 12 13 14 15 16 14 15 16 17 18 19 20 14 15 16 17 18 19 20
Washington, D.C.
17 18 19 20 21 22 23 21 22 23 24 25 26 27 21 22 23 24 25 26 27
April 2021
24 25 26 27 28 29 30 28 28 29 30 31 6-9 Dakota School of Lending Principles -
31 Radisson Hotel, Bismarck
12 Human Resource Management School
APRIL 2021 MAY 2021 JUNE 2021 Graduate School of Banking - Wisconsin
S M T W T F S S M T W T F S S M T W T F S Virtual starting April 12
1 2 3 1 1 2 3 4 5 27 Bank Technology Management School
Graduate School of Banking - Wisconsin
4 5 6 7 8 9 10 2 3 4 5 6 7 8 6 7 8 9 10 11 12 Virtual starting April 27
11 12 13 14 15 16 17 9 10 11 12 13 14 15 13 14 15 16 17 18 19 June 2021
18 19 20 21 22 23 24 16 17 18 19 20 21 22 20 21 22 23 24 25 26 6-11 Dakota School of Banking -
University of Jamestown
25 26 27 28 29 30 23 24 25 26 27 28 29 27 28 29 30
14-15 Quad States Convention -
30 31 Rushmore Plaza Civic Center
Rapid City, SD
JULY 2021 August 2021 SEPTEMBER 2021
21 SDBA National School for Experienced
S M T W T F S S M T W T F S S M T W T F S
Ag Bankers - Black Hills State University,
1 2 3 1 2 3 4 5 6 7 1 2 3 4 Spearfish, SD
4 5 6 7 8 9 10 8 9 10 11 12 13 14 5 6 7 8 9 10 11 July2021
11 12 13 14 15 16 17 15 16 17 18 19 20 21 12 13 14 15 16 17 18 18-30 Graduate School of Banking at Colorado-
Boulder, CO
18 19 20 21 22 23 24 22 23 24 25 26 27 28 19 20 21 22 23 24 25
August 2021
25 26 27 28 29 30 31 29 30 31 26 27 28 29 30 31
1-13 GSB 2021 Graduate School of Banking-
University of Wisconsin - Madison
2
CoNTeNTS
EXECUTIVE COMMITTEE
30 16 CHAIRMAN
Jolene Muscha
CHAIRMAN-ELECT
Christie Obenauer
TREASURER
Kathy Torske
The Union Bank of Union State Bank American Trust Center
Glen Ullin Hazen Bismarck
NDBA BOARD OF DIRECTORS
Deneen Axtman Brian L. Johnson Kelly Rachel
Cornerstone Bank Choice Bank Unison Bank
Fargo Grand Forks Jamestown
Judd Graham Craig Johnson Kim Settel
Bremer Bank Merchants Bank Gate City Bank
22
Fargo Rugby Fargo
Todd Heilman Jay Lies Todd Steinwand
Western State Bank Choice Bank Bank of North Dakota
Devils Lake Fargo Bismarck
FEATURES
Ryan Hertz Pat Lorenson Lee Weisbeck
11 SBA PPP: Myth vs. Fact Dacotah Bank Ramsey National Bank Starion Bank
Minot Fargo Mandan
16 2021: An Odyssey Away from LIBOR
Pete Jahner Brad Miller
20 Municipal Credit Update: Revisiting the Pandemic’s Kirkwood Bank and Trust
Bismarck
First State Bank of Cando
Cando
Effect on Municipal Credit Risk
22 Live Well Work Well: Celebrating Holidays Safely
NDBA SERVICES, INC. BOARD OF DIRECTORS
During the COVID-19 Pandemic CHAIR
Jeremy Skoglund Darren Haugen Bernie Sinner
28 COVID-19's Impact on 2021: Why Bankers Need to Bank of North Dakota Starion Bank BankNorth
Be Prepared Bismarck Mandan Casselton
30 Social Happenings Lois Bednar Kelly Hoeven Jeff Weiler
Bank Forward Bank of Glen Ullin Bank of North Dakota
Fargo Glen Ullin Bismarck
IN EVERY ISSUE Duane Bowman Jamie Nelson
Farmers Security Bank
2 Calendar of Events Dakota Western Bank
Bowman Washburn
3 NDBA Directors & Staff
4 Articles
12 NDBA Education Events & Webinars
NDBA STAFF
34 Happenings Rick Clayburgh Lisa Dolajak Ann Reich
President and CEO Communications and SVP of Strategic Partnerships
38 Banker Classifieds rick@ndba.com Marketing Coordinator ann@ndba.com
lisa@ndba.com
Jackie Bauer
Business and Database Jolene German NDBA GENERAL
Coordinator Administrative Assistant COUNSEL
jackie@ndba.com jolene@ndba.com
Tracy Kennedy
Mission Statement Angi Day Dorothy Lick tracy@ndba.com
Benefits Coordinator SVP of Education
angi@ndba.com dorothy@ndba.com
Extraordinary Leadership for North Dakota Banks
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Security Vendor Reports Major NDBA, ABA and State Banking
Supply Chain Cyberattack Trade Associations ask Congress
Affecting Government, Private to Extend CARES Act TDR Relief
Clients NDBA joined the ABA and
the and 50 other state banking
A major cyber-attack on SolarWinds – a security vendor that
trade associations on a letter to
serves a wide range of military, private companies, government
Congress asking them to extend
agencies, and academic institutions – may have allowed hackers
the troubled debt restructuring
to gain access to the emails, systems and data of several of its
(TDR) relief provisions in the CARES Act. The provisions,
clients, including the Treasury and Commerce Departments,
which are scheduled to expire this month, allow banks to suspend
among others. Suspected Russian hackers targeted SolarWinds’
generally accepted accounting principles for COVID-19 related
Orion business software with a “supply chain attack,” through
loan modifications.
which malicious code was embedded within a routine software
update that was distributed to SolarWinds’ clients. The letter notes that when a loan is classified as a TDR, a bank
is often required to hold twice the regulatory capital of current
The Cybersecurity and Infrastructure Security Agency issued
loans and is ineligible for consideration as collateral at the Federal
an emergency directive noting that the breach “poses an
Reserve. Many times, the TDR classification also forces the bank
unacceptable risk” and directing federal agencies to take steps
to take remedial steps against a loan, including foreclosure.
to disconnect or shut down use of affected SolarWinds Orion
products. SolarWinds also issued a security advisory to its users In related news, a group of Republican members of Congress
with more detailed instructions. also recently wrote to the House leadership asking for the
TDR provisions to be extended, stating that allowing them to
To read the CISA directive, visit: https://cyber.dhs.gov/ed/21-01/
expire "would have a drastic and adverse impact on the ability
To read the SolarWinds security advisory, visit: https:// of consumers and businesses to access credit now and a TDR
www.solarwinds.com/securityadvisory classification would further hurt their ability to access credit in
the future."
Community Banks Took on To read the letter, visit: https://www.aba.com/advocacy/policy-
Significant Share of PPP Lending analysis/joint-aba-and-sba-letter-to-hfsc-and-sbc-tdr-relief-extension
Community banks took on an
immense share of PPP lending, NDBA, ABA and State
according to a blog post by Associations Call for Keeping
the Conference of State Bank
Supervisors. Nationwide, community
GLBA Exemption in New Privacy
banks’ outstanding balance of PPP loans to total assets was Law
6.04%, compared to 1.81% for non-community banks. NDBA joined the ABA and the and 50 other state banking
Through the PPP, allocated 4.89 million forgivable loans were trade associations on a letter to the Uniform Law Commission –
made, totaling more than $521 billion, and community banks which has been tasked with drafting a uniform law on consumer
made 28% of the loans, or $148 billion. The total share of PPP privacy – urging it to retain in the draft the current exemption for
loans by community banks was much higher than their 12% information subject to the Gramm-Leach-Bliley Act. The letter
share of total industry assets and 15% share of total industry was sent ahead of a December meeting that took place to discuss
loans, CSBS said. the draft law.
"Community banks’ relationship approach to lending allows The associations responded to arguments made in a comment
them to make decisions and provide solutions to small letter by another advocacy group, which argued that GLBA
businesses,” CSBS said. “For many small businesses, community fails to offer adequate consumer protections and urged the
banks are often the only way to access loans and other financial committee to exclude the compromise exemption. In rebutting
services, which may help explain why the PPP participation rate the arguments, the associations noted that banking is the only
for community banks is so high." industry that is regularly examined by federal regulators on
compliance with federal privacy laws, which provides significant
To read more, visit: https://www.csbs.org/newsroom/community-
consumer protections.
banks-play-outsized-role-ppp-lending
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“The GLBA not only mandates disclosure of privacy practices Among other things, the final rule addresses the application of the
and information sharing restrictions, but it further requires “prudence and exclusive purpose” duties under ERISA to proxy
financial institutions to establish an information security program voting; the use of written proxy voting policies and guidelines;
that protects customer information,” the associations wrote. and the selection and monitoring of proxy advisory firms. ERISA
“Each program must be designed to ensure the security and fiduciaries may further adopt one or more of the rule’s optional
confidentiality of customer information, protect against any safe harbors to assist them in complying with the decision on
foreseeable risks, protect against its unauthorized access or use, whether to vote proxies.
and ensure its proper disposal.” They also emphasized that banks
To read the letter, visit: https://www.dol.gov/sites/dolgov/files/
regularly undergo full-scope, on-site examinations by the federal
EBSA/temporary-postings/fiduciary-duties-regarding-proxy-voting-
banking agencies to ensure compliance. and-shareholder-rights-final-rule.pdf
To read the letter, visit: https://www.aba.com/advocacy/policy-
analysis/joint-aba-and-state-association-alliance-letter-to-ulc-privacy CFPB Issues Final QM Standard Rule
The CFPB has issued a final rule
Banking Agencies Provide Relief making several changes to the
to Community Banks with Qualified Mortgage (QM) standard.
Pandemic-Inflated Assets The rule defines both the general QM
category and a new “seasoned” QM
The federal banking agencies have issued an interim final rule standard for certain portfolio loans.
to ease the regulatory burden of community banks that have
experienced sudden asset growth as a result of participation Under the rule, to receive the QM safe harbor the annual
in COVID-19 relief programs like the Paycheck Protection percentage rate on a covered transaction must not exceed the
Program. The Fed noted that many community banks have annual prime offer rate for a comparable transaction by 1.5
experienced an unexpected and sharp increase in assets, swelling percentage points. Loans with an APR that exceeds the APOR
their balance sheets in some cases by more than 25%, but that by 1.5 to 2.25 percentage points will receive a QM rebuttable
growth is expected to be temporary. presumption of ability to repay, with higher pricing thresholds set
for smaller loan amounts, manufactured home loans and certain
The rule gives community banks with less than $10 billion in other transactions.
assets as of Dec. 31, 2019, more time to either reduce their
balance sheets by shedding temporary growth or to prepare for For the general QM requirements, the rule also eliminates the 43
higher regulatory and reporting standards. According to the rule, percent debt-to-income threshold and the underwriting definition
asset growth in 2020 or 2021 will not trigger new regulatory contained in Appendix Q while retaining the product feature and
requirements for those community banking organizations until underwriting requirements and points-and-fees limits. The rule
Jan. 1, 2022, at the earliest. The rule does not provide relief from also mandates that lenders consider the consumer’s income or
CFPB regulatory and supervisory thresholds, nor does it affect assets, debt obligations and DTI ratio or residual income.
compliance with the Volcker Rule. The seasoned QM standard applies to mortgages held in
To read more, visit: https://www.federalreserve.gov/newsevents/ portfolio that have met certain performance requirements over a
pressreleases/files/bcreg20201120a1.pdf 36-month seasoning period, including having no more than two
delinquencies of 30 or more days and no delinquencies of 60 or
more days. To receive seasoned QM status, loans must be secured
DOL Finalizes Rule on Proxy Voting by a first lien; have a fixed rate with fully amortizing payments
The Department of Labor has issued and no balloon payments; must not exceed 30 years in term; and
a final rule formalizing requirements have total points and fees under specified limits.
regarding a fiduciary’s proxy voting To read more, visit: https://www.consumerfinance.gov/about-us/
activity under the Employee Retirement newsroom/consumer-financial-protection-bureau-issues-two-final-
Income Security Act. The final rule rules-promote-access-responsible-affordable-mortgage-credit/
requires that fiduciaries carry out their
duties related to proxy voting solely in
accordance with the economic interest of
retirement investors. The rule becomes part of DOL’s investment
duties regulation, which includes the recently finalized DOL rule
on ESG investments.
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SBA Guidance Indicates that ineligible to receive the loan amount or loan forgiveness amount
claimed by the borrower (or the loan forgiveness amount in the
Banks Must File 1099/1098 for lender’s forgiveness decision).”
CARES Act Loan Subsidies Lenders may contact PPPForgivenessRequests@sba.gov with
The SBA has issued a Q&A document questions.
regarding several tax issues related to
payments made on behalf of borrowers FDIC Analysis Examines
to lenders for existing SBA 7(a), 504 and
microloans. The CARES Act required the
Community Bank Economies of
SBA to make payments covering six-months Scale
of principal, interest and any associated fees small businesses may The FDIC has released a staff study highlighting how economies
owe on these loans. of scale developed at community banks (those with $10 billion or
The guidance notes that lenders must file a Form 1099-MISC less in assets) between 2000 and 2019. Between that period, the
indicating the amount of principal, interest and any fees paid by FDIC estimated that “the cost-minimizing size of a bank’s loan
SBA to the lender on behalf of the borrower. In situations where portfolio rose from approximately $350 million to $3.3 billion,”
lenders received payment subsidies for loans for which a Form suggesting that “efficiency gains accrue early as a bank grows from
1098, Mortgage Interest Statement is due, SBA also said that $10 million in loans to $3.3 billion, with 90% of the potential
form should be filed by the lender. efficiency gains occurring by $300 million.”
To view the Q&A, visit: https://www.sba.gov/sites/default/files/ At that size, the report noted that banks have estimated costs of
articles/5000-20067.pdf about 4.76%. Banks with a loan portfolio of double that size –
around $600 million – have estimated costs of 4.33% and have
SBA Outlines Procedures for PPP accrued 95% of the potential cost savings as a result of their
increased size, the FDIC said.
‘Loan Necessity’ Questionnaires The report also found that the financial crisis “temporarily
The SBA has released procedures for interrupted this trend and costs increased industrywide, but a
lenders in handling the loan necessity generally more cost-efficient industry reemerged, returning in
questionnaires that SBA is requesting recent years to pre-crisis trends.”
for PPP loans totaling $2 million or
To read more, visit: https://www.fdic.gov/analysis/cfr/staff-
more. The procedures were detailed in a
studies/2020-06.pdf
user guide and introductory letter sent
using SBA’s PPP forgiveness platform.
According to the documents, lenders will receive notice of
FTC Consumer Alert Warns
requests from SBA for questionnaires via the SBA forgiveness of Potential Fraud Related to
platform at forgiveness.sba.gov. The questionnaires – SBA Form COVID-19 Vaccines
3509 for for-profit borrowers and Form 3510 for nonprofit
borrowers – are available there, and the platform now accepts With multiple promising COVID-19
online submission of the completed questionnaires. Lenders vaccines on the horizon, a new consumer
must notify the borrower of the request within five business days alert from the Federal Trade Commission
and should advise the borrower to complete the form within 10 is warning consumers of potential fraud
business days, SBA said. Lenders must upload the completed scams associated with the vaccines. The
questionnaire, manually enter borrower responses and upload FTC outlined several facts that can help
supporting documentation within five business days of receiving consumers steer clear of potential scams.
it. For example, the FTC said that consumers will likely not have
While reiterating that lenders are not required to verify or validate to pay out of pocket to receive the vaccine; will not be able to
the borrower’s responses or supporting documentation submitted pay to put their name on a list to receive the vaccine or receive
with the questionnaires, SBA emphasized in its letter that “failure early access; and will not be contacted by a representative from
to timely respond to any SBA request may result in a delay in a vaccine distribution site or health care payer asking for their
SBA’s remittance of the loan forgiveness amount, if any, or in a Social Security number or bank account information in order to
determination that the borrower was ineligible for the loan or sign up to receive the vaccine. The FTC also urged consumers to
be wary of providers offering products, treatments, or medicines
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to prevent the virus, and to consult their healthcare provider bank level and one at the assessment area level for the top three
before paying for or receiving any kind of COVID-19 treatment. CRA ratings. The CD minimum involves two values, one at the
bank level and one at the assessment area level.
If a scam is suspected, the FTC directed consumers to report it by
visiting ReportFraud.ftc.gov or filing a complaint with their state The proposal also makes clarifying and technical changes to the
attorney general through consumerresources.org. CRA final rule. Comments are due 60 days after publication in
the Federal Register.
OCC Proposes Fair Access to To read more, visit: https://www.occ.gov/news-issuances/news-
Banking Services Rule releases/2020/nr-occ-2020-160.html
The OCC has issued a proposed rule
requiring banks to provide access to
SBA Releases Data on PPP/EIDL
services, capital, and credit based on their Loans
risk assessment of individual customers In response to a federal judge’s order, the SBA has released
and not make decisions that affect entire borrower information on both the PPP and EIDL programs.
categories of customers. The proposed SBA declined to appeal a judge's order in a case brought by
rule, which covers national banks and multiple news organizations seeking data more granular than what
federal savings associations with more than $100 billion in SBA has already disclosed.
assets, prohibits institutions from denying services in an effort to
disadvantage or otherwise hinder the customer from competing While it is not unexpected that details of a government loan
in a market or business segment or benefiting another person or program would eventually be made public, banks can expect
business activity. media attention on the PPP and EIDL data. Banks should
consider reviewing the data reported for their borrowers to ensure
In issuing the rule, the OCC cited a provision in the Dodd- accuracy.
Frank Act that charges the agency with “assuring the safety and
soundness of, and compliance with laws and regulations, fair To view the SBA data, visit: https://sba.app.box.com/s/5myd1nxu
access to financial services, and fair treatment of customers by, toq8wxecx2562baruz774si6
the institutions and other persons subject to its jurisdiction.” For concerns about publicly released EIDL data, please
The agency noted that the proposal is in response to some email: disastercustomerservice@sba.gov
banks no longer financing specific kinds of businesses, such as
To request an update (correction) to PPP loan
gun manufacturers, fossil fuel companies, and private prisons.
information, visit: https://www.sba.gov/ppp-data-feedback
Comments on the proposal are due by January 4, 2021.
To read more, visit: https://www.occ.gov/news-issuances/news-
releases/2020/nr-occ-2020-156.html
Senate Approves Waller to Serve
on Fed Board of Governors
OCC Releases Proposal on CRA The U.S. Senate has approved the nomination of Christopher
Performance Standards Waller to serve on the Federal Reserve Board of Governors on a
party-line vote of 48 to 47. Waller, who currently serves as the
The OCC has released a proposal detailing the agency’s approach director of research at the Federal Reserve Bank of St. Louis, will
to determining Community Reinvestment Act evaluation serve a term on the Fed Board that expires in January 2030.
measure benchmarks, retail lending distribution test thresholds
and community development minimums. The proposal further
implements the new general performance standards outlined in
IRS Clarifies Deductibility of
the CRA final rule issued earlier this year. Qualified PPP Expenses
The proposal states that the OCC plans to survey the industry to The IRS has issued a ruling that borrowers
gather bank-specific information from institutions subject to the submitting Paycheck Protection Program
general performance standards. This information will be used loan forgiveness applications for approval are
to help calculate CRA evaluation measures and CD minimum required to disallow a deduction for qualified
calculations for each bank’s assessment areas, as well as a bank- 2020 expenses in 2020 tax returns, even
level CRA evaluation measure and CD minimum calculations. when the forgiveness application has not been
The evaluation measure includes six benchmark values: one at the approved or filed by the end of the year. The ruling was issued
in response to questions raised about non-deductible expenses in
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situations where the expenses are paid in 2020 and the forgiveness • Includes a requirement for the insurer to give a written 45-
of the loan may not occur until 2021. day notice before nonrenewal or cancellation
The agency also issued a revenue procedure that provides • Includes information about coverage available under the NFIP
guidance for PPP borrowers that either do not apply for
• Includes a mortgage interest clause
forgiveness or have all or part of the forgiveness application
denied. • Includes a provision requiring an insured to file suit not
later than one year after a date of a written denial for all or
To read the IRS ruling, visit: https://www.irs.gov/pub/irs-drop/
part of a claim
rr-20-27.pdf
• Contains cancellation provisions that are as restrictive as the
To read the revenue procedure, visit: https://www.irs.gov/
provisions contained in an NFIP policy.
pub/irs-drop/rp-20-51.pdf
“In the event of a lapse in the NFIP, the option of private flood
Fed to Extend Some Lending insurance may reduce the likelihood of delays in the processing
of new originations,” HUD said. “Acceptance of private flood
Facilities Through March insurance policies would additionally benefit borrowers who want
The Federal Reserve has announced that it FHA-insured mortgages, by providing them consumer choice,
would extend several lending facilities that including the opportunity to obtain private flood insurance
were set to expire on or around Dec. 31 to policies that may be more affordable than NFIP policies.”
March 31, 2021. The extensions apply to To read the proposal, visit: https://www.federalregister.gov/
the Commercial Paper Funding Facility, documents/2020/11/23/2020-25105/acceptance-of-private-flood-
the Money Market Mutual Fund Liquidity insurance-for-fha-insured-mortgages
Facility, the Primary Dealer Credit Facility
and the Paycheck Protection Program Liquidity Facility.
FDIC Finalizes Changes to
The Fed said the extension is intended to aid planning by
potential participants and provide certainty that the facilities will
Brokered Deposit Rules
be available through the first quarter of 2021 to help the economy The FDIC has finalized changes to modernize its existing
recover from the COVID-19 pandemic. brokered deposit rules and foster greater innovation by financial
institutions. The final rule establishes a new framework for
To read more, visit: https://www.federalreserve.gov/newsevents/
designating an entity as a “deposit broker” and amends the
pressreleases/monetary20201130a.htm
methodology for calculating the national rate and national rate
cap for specific deposit products.
HUD Proposes to Allow Private The final rule narrows the definition of “deposit broker.” It also
Flood Insurance for FHA-Insured designates certain business relationships and services that meet
Mortgages the rule’s “primary purpose exemption,” and do not require an
application to the FDIC. These designated exemptions include:
The Department of Housing and Urban deposits where the agent has less than 25% of the total “assets
Development has proposed a rule to allow under administration” for its customers; health savings accounts;
mortgagors the option to purchase private deposits related to certain real estate and mortgage servicing
flood insurance on Federal Housing transactions; certain retirement funds; and customer funds held
Administration-insured mortgages for for various regulatory, tax and other government purposes.
properties located in Special Flood Hazard
Areas. Comments on the proposal are due To better accommodate fintech partnerships, the rule also
60 days after publication in the Federal provides that entities with exclusive deposit placement
Register. arrangements with one bank are not deposit brokers. With respect
to the national rate cap, the FDIC would include credit unions
The proposed rule defines private flood insurance as an insurance in the data that backs the national rate and incorporate Fed funds
policy that, among other things: and Treasury rates into the national rate cap.
• Is issued by a licensed or approved insurer in the state or To view the final rule, visit: https://www.fdic.gov/news/
jurisdiction where the property is located board/2020/2020-12-15-notice-dis-a-fr.pdf
• Provides coverage that is at least as broad as that provided
under a standard National Flood Insurance Program policy
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Labor Department Finalizes
Agencies Propose Rule Regarding Fiduciary Investment Advice
Timely Notification of Cyber Exemption
Attacks The Department of Labor has finalized
Federal regulators have approved its proposed class exemption on fiduciary
a new proposed rule that would investment advice. Available to banks
require banks to notify their and other investment advice fiduciaries,
primary regulator within 36 the exemption would permit receiving
hours of becoming aware that compensation as a result of providing
a “computer-security incident” fiduciary investment advice, including
or “notification incident” has advice to roll over a participant’s account
occurred. The rule would also in an employee benefit plan to an individual retirement account
require bank service providers to notify “at least two individuals and other similar types of rollover recommendations.
at affected banking organization customers immediately after the
The exemption requires fiduciary investment advice to be
bank service provider experiences a computer-security incident
provided in accordance with the following “impartial conduct
that it believes in good faith could disrupt, degrade, or impair
standards” to advance retirement customer protections: a best
services provided for four or more hours.”
interest standard; a reasonable compensation standard; and a
The rule defines a computer-security incident as an occurrence requirement to make no materially misleading statements about
that results in actual or potential harm to the confidentiality, recommended investment transactions. The exemption includes
integrity or availability of an information system or the other protections that would require disclosures to retirement
information the system processes, stores or transmits; or investors, conflict mitigation and a retrospective compliance
constitutes a violation or imminent threat of violation of security review. DOL said this approach further will preserve wide
policies, security procedures or acceptable use policies. It defines a availability of investment advice arrangements and products for
notification incident as one that could materially disrupt, degrade retirement investors.
or impair bank operations or the delivery of bank products and
The exemption takes effect 60 days after publication in the
services, among other things. This notice requirement is intended
Federal Register.
to signal the occurrence of a significant material event; based on
a review of FinCEN reports, the banking agencies anticipate that To read more, visit: https://www.dol.gov/sites/dolgov/files/EBSA/
incidences of this type (such as ransomware, Trojan malware, zero temporary-postings/final-exemption-improving-investment-advice-
day attack, etc.) occur approximately 150 times annually across for-workers-and-retirees.pdf
the aggregate financial services industry.
Under the proposed rule, banks would be required to notify their Ask Kennedy: NDBA Monthly FAQs
regulator “as soon as possible and no later than 36 hours after Coming in 2021! North Dakota Bankers
the banking organization believes in good faith that the incident Association announces "Ask Kennedy", a
occurred.” The agencies added that the requirement “is intended new monthly series in which Tracy Kennedy,
to serve as an early alert to a banking organization’s primary NDBA General Counsel, reviews the
federal regulator and is not intended to provide an assessment of questions she has received from member
the incident.” Comments will be due 90 days after publication in banks over the past month. Hear the
the Federal Register. issues other banks are facing and find out
To view the proposed rule, visit: https://www.fdic.gov/news/ the anwers as well! Tracy will discuss the Tracy Kennedy
board/2020/2020-12-15-notice-sum-c-fr.pdf questions and answers via 45 minute live
broadcast and written bulletin, both released through NDBA
each month. First virtual event will be held Wednesday, January
6. Visit ndba.com for more information.
9
BEYOND THE FUNDAMENTALS
National School
for Experienced Ag Bankers
Photos by South Dakota Tourism
JUNE 21-24, 2021
BLACK HILLS STATE UNIVERSITY...”Where Anything Is Possible”
SPEARFISH, SOUTH DAKOTA
10Myth vs. Fact unemployment far lower than expected at the peak of the
pandemic. In addition, the unemployment rate is currently
MYTH #1: PPP is wrought with waste, 6.7%, a rate not expected to be achieved by many outside
fraud, and abuse. experts until the fourth quarter of 2021.
FACT: The vast majority of PPP funds supported American MYTH #4: PPP funds did not reach
small businesses and their hardworking employees in dire historically underserved communities.
need of economic relief. To ensure all program rules were
followed, all loans are undergoing an automated review, and FACT: Since enactment of the CARES Act, SBA and Treasury
all loans of $2 million or more will undergo a manual review. worked closely with Congress, borrowers, and lenders of all
In addition, any loan may be selected for a manual eligibility sizes – including regional and community banks, Community
review or forgiveness review. SBA has a robust process for Development Financial Institutions (CDFIs), and Minority
ensuring PPP funds were used as intended. SBA is committed Depository Institutions (MDIs) – to make certain the broadest
to rooting out fraudulent activity; any abuser of this important possible segment of small businesses could access the
program will be held appropriately accountable. A business PPP. To ensure funds began flowing as rapidly as possible
listed in the data release doesn’t mean that SBA has made an to all small businesses, particularly those in underserved
affirmative declaration that a borrower is eligible or that it will communities, SBA and Treasury worked closely with lenders
receive loan forgiveness. SBA has a process for review and that were positioned to reach borrowers who had had less
well-established traditional banking relationships. Through
that is ongoing.
our actions, we increased the number of participating lenders
MYTH #2: PPP only supported large from the 1,700 that participated in SBA 7(a) lending in 2019 to
nearly 5,500 lenders participating in the PPP.
corporations, not small businesses.
SBA and Treasury executed an aggressive outreach campaign to
FACT: The PPP was deployed to help keep small businesses
ensure PPP participation by CDFIs, MDIs, and minority, women,
afloat and employees on payroll through the coronavirus
veteran, or military-owned lenders due to their unmatched
pandemic. Of those businesses that received PPP loans, 75
ability to reach underserved communities. The data shows that
percent have nine or fewer employees. In addition, 87% of
SBA and Treasury’s outreach campaign worked.
all loans, or nine out of ten, were $150,000 or less. Every
eligible independent contractor, sole proprietor or small As of August 8, 2020, when the PPP closed to new loan
business that applied for a PPP loan – whether it employed applications, 432 MDIs and CDFIs had participated from
hundreds of workers or a single individual – received one. The across the country, providing over 221,000 loans for more
PPP closed in August with more than $130 billion in available than $16.4 billion. PPP delivered $133 billion of loans to
funding that went unclaimed. businesses in Historically Underutilized Business Zones,
accounting for more than 25 percent of all PPP funding.
MYTH #3: PPP did not support workers. Additionally, a review of census tracts indicates 28 percent of
the U.S. population lives in low and moderate income census
FACT: Every facet of PPP was designed to keep Americans
tracts, and when matched against the distribution of PPP
employed. The PPP has succeeded. To date, PPP has
loans, 27 percent of the PPP funds went to low and moderate
supported more than 51 million American jobs, and account
income communities, which is in line with their representation
for more than 80% of small business payroll in the United
States. By requiring at least 60% of PPP funds to cover payroll in the population. n
costs, the Administration ensured Americans’ paychecks
were protected. The PPP directly contributed to the historic
economic recovery we are currently experiencing, keeping
11North Dakota Bankers Association
Education Events
For more information regarding these educational opportunities,
visit www.ndba.com or contact Dorothy Lick, SVP of Education,
North Dakota Bankers Association, 701.223.5303.
EVENT DATE LOCATION WHO SHOULD ATTEND?
UCC Article 9 Virtual February 16, 23 Virtual Both entry-level and experienced lenders will
& March 2 gain valuable information.
Seminar
Dakota School of April 6-9 Radisson Hotel, Bismarck Loan officer trainees, loan support personnel and
personal bankers.
Lending Principles
Tri-State Trust April 27-29 Delta by Marriott Trust officers, trist attorneys, CTFAs and CFPS.
Conference Fargo, ND
Dakota School of June 6-11 University of Jamestown, Attendees are generally first-or mid-level managers
Jamestown, ND seeking advancement in their banks and careers.
Banking However, others who would benefit from exposure
to the banking industry and increased familiarity
with the individual components that make up a
bank are also encouraged to attend.
Quad States June 14-15 Rushmore Plaza Civic Center Presidents, CEOs, senior management staff,
Rapid City, SD lenders, marketing team members and sales
Convention managers.
National School June 21 Black Hills State University Experienced ag bankers who want to further
Spearfish, SD develop their ag lending skills, learn new skills,
for Experienced Ag confirm existing methodology and meet fellow
Bankers bankers who share the same career path.
Group Meetings September 13-16 Grand Forks, Fargo, Bismarck All NDBA members!
and Minot
12Upcoming
Bank Webinars NDBA offers convenient bank training and access
to timely topics through a variety of webinars.
EVENT DATE EVENT DATE
Online Account Opening January 5 Working Remotely - Prepare January 14
for the New Normal
Employment Law Overview: January 5
Keeping Up With the Times The Transition Away from January 15
and Avoiding Pitfalls LIBOR
Let’s Face It! The Constant January 6 BSA Officer Annual Training January 19
Threat of Social Engineering Ratio Analysis to Determine January 19
Best-Ever Compliance January 6 Financial Strength
Checklists for Consumer IRA Update - Information and January 20
Loans Clarification
Writing an Effective Credit January 7 Compliance Management January 21
Memorandum
Bank Accounting for January 21
Basics of Banking: An January 7
Beginners - 4 Part Series
Overview
Bank Accounting for January 21
Basic Business Entities & January 11
Beginners - Part 1
Other Commercial Borrowers
Basic Real Estate Loan January 22
Have You Updated Your January 12
Documentation
Business Continuity
Management To Meet Bank Accounting for January 25
Regulatory Expectations Beginners - Part 2
Writing Teller Training and January 12 Creating the Right ERM January 26
Procedures Program for YOUR
Community Bank
Dealing with Subpoenas, January 13
Summonses, Garnishments, Opening Business Accounts January 26
Tax Levies, Etc.
For more information, visit www.ndba.com and
Regulation Z Rules for Home January 13
Equity Lines of Credit click on “Education” and then “Web Seminars.”
13Our EXPERTISE, Your Piece of Mind
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while still earning revenue!
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efficient, making your customer’s journey
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let's work together!
Call or e-mail Dan to learn why over 100+
partners rely on our mortgage expertise
everyday and how we can help you!
Dan Van Winkle
Mortgage Consultant, NMLS 8495
701-356-9898 | Dan@firstclasscorp.com
www.firstclasscorp.com NMLS 2520 • 2300 13th Avenue South, Fargo ND
14Together, let ’s
make it happen.
Callie Schlieman
Call me at 701.433.7430
Based in Fargo, N.D., specializing in bank stock and Regulation O lending
Why choose Bell as your bank’s lending partner?
We’re providing loans to banks across the country for capitalization, acquisitions,
refinancing and restructuring. We’ll tailor terms and conditions to your bank and its owners.
Bank stock & ownership loans Bank building financing Business & personal loans for bankers Commercial & ag participation loans
24873
Member FDIC
15BUSINESS PARTNERfeature article
2021: An Odyssey Away from LIBOR
benchmark rate would be discontinued beginning December
31, 2021. This discontinuation meant that many businesses,
banks included, would have to take the arduous transition
away from using LIBOR in the future as well as address
Tim Dominguez, existing products that already use it.
Associate General Counsel
Compliance Alliance Under normal circumstances, 2020 was supposed to be a
significant year in the transition away from LIBOR. However,
The 1980s were a much different time than today to say the the financial impact of the COVID-19 pandemic may have
least. Many of us remember or are too young to remember caused a shift in priorities for many banks. While regulators
an age where the typical computer only had sixty four have provided temporary reprieve in several areas of banking
kilobytes of memory or where cell phones weighed as much for this year, it still stands today that LIBOR will no longer
as twenty pounds with no one anticipating we would ever call be here after 2021. To underscore the crucial need to address
them smart any time soon. The 1980s were also a period of this issue by that deadline, the Financial Security Board (FSB)
change for global economics and banks. In 1986 the London published a 2020 Progress report on the year of transition
Interbank Offering Rate (LIBOR) was officially introduced away from LIBOR. As the transition remains a global priority,
and published as an interest rate benchmark for widespread the FSB also included a roadmap of milestones that banks
usage by both financial and non-financial firms in response should follow as a guidance in navigating this process in a
to banks trading in new interest markets. However, over three timely manner.
decades later after determining that LIBOR was vulnerable The FSB report addresses how the COVID-19 pandemic
to interest rate manipulation, it was announced that the has been a “defining feature of the past year with widespread
16implications.” Understandably so, the pandemic has impacted before the end of the year and consummate those changes
many firms in their transition away from LIBOR, but where parties can agree. New contracts should contain robust
according to a survey of FSB members, it has not created alternative reference rates wherever possible by this time.
pressing substantive roadblocks to the transition. In fact, the
By the end of 2021, banks should be fully prepared for LIBOR’s
report states that the direct correlation between LIBOR and
discontinuation. At this point, all new business should involve
banks’ overall borrowing costs weakened during the pandemic
alternative rates or at the very least be capable of switching in
with volatility leading banks to scarcely rely on LIBOR
a short amount of time. In cases where it was impossible to
markets for funding. Those that did use LIBOR rates faced
amend legacy contracts linked to LIBOR, the implications of
challenges because of the pandemic. While central bank rates
the benchmark rate no longer being published should have
were decreasing throughout the world, LIBOR rates were
already been discussed with necessary steps being taken to
increasing which were passed on to borrowers in a time when
prepare for this kind of outcome. The goal by December 31,
financial systems were supposed to play a role in providing
2021 is for all market participants, financial and non-financial
much needed liquidity.
firms alike to operate without relying on LIBOR. To meet
Despite pandemic induced market disruptions, the FSB states this, the importance of a market-led transition will remain
that progress has been made throughout the past year in the significant all throughout this year.
transition. Many national working groups have produced their
At the outset of LIBOR in 1986, it would be difficult to say
own timely roadmaps as guides that have been widely adopted
many could have predicted that over thirty years later the
while also considering the economic impact of COVID-19.
rate would be discontinued and that the transition would be
Over the past year, the FSB continued to work with the
impacted by a global pandemic. Just as 2020 was a significant
International Swaps and Derivatives Association (ISDA)
year for the transition away from LIBOR, 2021 is equally, if
to address the transition away from LIBOR in derivative
not, even more critical. If banks have not taken the necessary
contracts. In October 2020, ISDA released amendments to
steps to address their potential LIBOR exposure for new and
its definitions and protocols with these contracts and included
existing products, they must immediately put plans in place.
new fallback language that can be used by firms. This past year,
The 1980s were indeed a different time compared to today.
more have adopted the Secured Overnight Financing Rate
Just like computers with negligible storage space and phones
(SOFR) as the preferred alternative in U.S. dollar markets.
as heavy as a sledgehammer, LIBOR is about to be an element
Significant process has indeed been made and while regulators
left behind in the past. As we have adapted to changes in
have launched a number of initiatives, what remains is for both
technology, banks must also adapt to this change by properly
financial and non-financial firms to globally lead the effort to a
preparing themselves and their customers. n
timely market transition by no longer issuing products linked
to LIBOR and by modifying their legacy contracts linked to Tim Dominguez joins Compliance Alliance after graduating
LIBOR wherever possible. from the University of Houston Law Center. During law school,
he worked as an intern within the legal department of Frost
At this moment in time, the FSB Global Transition Roadmap
Bank in San Antonio, TX. He also holds a Bachelor of Science in
states that firms should already at a minimum have identified
Communication Studies from The University of Texas at Austin.
all existing LIBOR exposures including what will happen after
Before law school, Tim worked various jobs within the Texas state
2021 and if those contracts have any fallback measures in place.
government, including the Texas Senate and the Texas Legislative
Further, those who provide customers with products that
Council. As one of our hotline advisors, Tim provides guidance
reference LIBOR must have a plan in place to communicate
to C/A members on a wide variety of regulatory and compliance
to them of the transition and the steps being taken by the bank
issues, in addition to writing articles for some of our publications.
to move to alternative rates. Banks should by now understand
industry and regulatory best practices with the transition
away from LIBOR including necessary steps taken with the
assistance of legal counsel. By mid-2021, banks should have
already determined which legacy contracts can be amended
17Your Charitable Giving Experts in North Dakota.
Kevin Dvorak, CFP® Amy Stromsodt, CFRE Kara Geiger, CFRE John Heinen, CFRE
Bismarck Grand Forks Bismarck Dickinson
701-222-8349 701-741-3193 701-222-8349 701-590-4614
Kevin@NDCF.net Amy@NDCF.net Kara@NDCF.net John@NDCF.net
Call us anytime for free, no obligation, confidential
consultations about these or other charitable giving topics:
The 40% state tax credit for gifts to qualified ND
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Charitable gift annuities and charitable remainder trusts
The IRA charitable rollover
Donor-advised funds
How to discuss charitable giving with your client
How to start an endowment fund for your community
www.NDCF.net/GivingExperts
18by
Stay lean and grow your bank’s compliance
program using Compliance Alliance.
Your resources are stretched thin – Why not put us to work for you?
We’re here to help you manage the load, while keeping your budget light
and your options open.
More about C/A Membership by calling (888) 353-3933 or emailing
compliancealliance.com at: info@compliancealliance.com
19BUSINESS PARTNERfeature article
Municipal
Credit
Update:
Revisiting the Pandemic’s Effect
on Municipal Credit Risk
“The potential impact of the COVID-19 pandemic on the City states did not cut funding to school districts in the 2020 fiscal year,
cannot be quantified at this time, but the continued outbreak of but instead used one-time budgetary maneuvers to make ends meet.
COVID-19 could have an adverse effect on the City’s operations If state revenues continue to be depressed, they may be forced to
and financial condition.” This disclosure, or something like it, make cuts across the board, including education. Vulnerability to
is now regularly included in documentation by municipal issuers. state funding changes can be measured by analyzing the district’s
While we would love to have more details than that, the exact dependence on state funds relative to total revenues. Of course,
magnitude of the pandemic’s repercussions on state and local further federal aid would mitigate this risk. Congress is working
finances still cannot be accurately determined. on ideas for more aid, but none have fully passed at this time. The
HEROES Act, passed by the House on October 1, 2020 but not
However, we do have some clarity on the results of the 2020 fiscal yet by the Senate, contains $676 billion in funds for state and local
year, given that most local government fiscal years close in June. governments with $208 billion specifically allocated for education
The U.S. Census Bureau reports that total state tax revenue declined spending. The HEROES Act comes with an important restriction:
29% in the second quarter of 2020 compared to the same quarter states may not cut their budgets for education spending, which will
in 2019. The chart below exposes the states with the largest declines help to further protect school districts from state funding cuts if
in total tax revenue when comparing Q2 2019 to Q2 2020. Most enacted.
20Also, the National League of Cities reveals that all major local tax while smaller cities like Jacksonville and Salt Lake City experienced
revenue sources slowed with severe declines in sales and income tax net gains in new residents.
receipts. Sales tax revenue dropped by 11% on average in the 2020
fiscal year. Property tax revenue continued to grow, but the growth Looking forward to the 2021 fiscal year, many questions linger.
rate slowed compared to 2019 and may continue to slow and even Cities and states are anticipating an even larger decline in general
decline in 2021 and 2022 depending on economic conditions. fund revenues than they experienced during 2020, reserve levels
Property tax trends are slow to follow economic fluctuations have lessened from pre-pandemic levels, and it is not clear when or if
because assessed valuations are typically set well in advance of the events and gatherings may resume regular schedules. Investors must
actual bills being due, and changes in assessed valuations are often continue to diligently monitor their holdings for potential credit
more muted than changes in market value due to caps on assessed deterioration as outlined in our earlier Municipal Credit Update
valuation increases and other calculation considerations. However, concerning the COVID-19 pandemic. (https://www.gobaker.com/
the longer the economy remains depressed, the more likely it is municipal-credit-update-managing-credit-risk-amid-the-covid-19-
that home prices will deteriorate and cause declines in property tax pandemic/) n
revenue absent rate increases. Dana Sparkman
Senior Vice President/Municipal Analyst
Certain downtown areas and other once busy areas that are now The Baker Group LP
much emptier because of people working from home may be Contact: 405-415-7223
particularly susceptible to property tax revenue declines as demand dana@GoBaker.com
for those expensive commercial spaces lessens, especially if the work- Dana Sparkman, CFA, is Senior Vice President/
from-home trend remains after the pandemic ends. Some large cities Municipal Analyst in The Baker Group’s
Financial Strategies Group. She manages a
may even experience de-urbanization if people choose to relocate to
municipal credit database that covers more
smaller cities in favor of more space and, in some cases, less taxes. than 150,000 municipal bonds, providing
According to LinkedIn, New York City and the San Francisco Bay clients with specific credit metrics essential
in assessing municipal credit. Dana earned
Area both recently experienced steep declines in their inflow-to- a bachelor’s degree in finance from the
outflow ratios with both cities losing more people than they gained University of Central Oklahoma as well as the
Chartered Financial Analyst designation.
21The Baker Group
Is Here to Help
As American financial institutions—along with
the rest of the world—face unprecedented times, Baker’s Software Solutions Service
The Baker Group is ready with tools and services
Package Includes:
to help maximize the performance of Asset/Liability Analysis – Interest Rate Risk Monitor (IRRM®)
Your management team will find that The Baker Group’s
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That’s why we’re offering new clients our
Liability Analysis is an effective tool in managing your
Software Solutions* service package for a risk and performance.
six-month free trial. Not only will you have Baker Bond Accounting® (BBA)
access to our latest market research and insight The Baker Group will provide you with accurate, easy-to-
read reports delivered electronically to you each month.
from our Financial Strategies Group, you’ll be
included in all of our webinars. There you’ll hear Investment Analysis – Advanced Portfolio Monitor (APM®)
The Advanced Portfolio Monitor is a key monthly report
the latest on how COVID-19 could impact your
that we utilize to help you measure, monitor, and manage
institution and its investment portfolio. the overall risk and performance of your investments.
To obtain the resources you need to maximize the performance of your
Member: FINRA and SIPC
bank, contact Ryan Hayhurst with our Financial Strategies Group
Oklahoma City, OK | Atlanta, GA
at 800.937.2257, or via email at Ryan@GoBaker.com. Austin, TX | Indianapolis, IN | Long Island, NY
Salt Lake City, UT | Springfield, IL
Ryan@GoBaker.com
www.GoBaker.com
*The Baker Group LP is the sole authorized distributor for the products and
services developed and provided by The Baker Group Software Solutions, Inc. 800.937.2257
22The Federal Reserve Bank of Minneapolis is hosting its fourth annual
Regional Economic Conditions Conference
The conference will focus on the economic impact of COVID-19 across the Ninth District, with special
attention paid to the pandemic’s impact on workers. The event will be keynoted by North Dakota
Governor Doug Burgum, who will talk about the challenges and opportunities for the Peace Garden
State. The conference will also feature presentations and panel discussions with prominent economists.
Wednesday, January 13, 2021 | 8:30 a.m. - 12:15 p.m. CT
Free and open to the public
Register now
Save the Date
April 6-9, 2021
Radisson Hotel
Bismarck, ND
Dakota School of
Lending Principles
23122 East Main Ave., Suite 201 | Bismarck, ND 58501 | p 701.223.5303 | e angi@ndba.com
Celebrating Holidays
BENEFIT TRUST
Safely During the
COVID-19 Pandemic
Live Well, Work Well Health and Wellness tips for your work, home and life
brought to you by ND BANKS Benefit Trust.
'Tis the season for holiday planning. Yet, gatherings • Avoid contact with people outside of your
of families and friends, crowded parties and travel household for 14 days before the gathering.
may put Americans at an increased risk for COVID-19.
Also, it’s important to stay home if you do not feel well
The Centers for Disease Control and Prevention (CDC)
or are at a higher risk for serious complications from
recommends that you carefully consider the spread risk
COVID-19.
of in-person holiday celebrations.
During a Gathering
Consider the following tips from the CDC to reduce
your risk of being exposed to, contracting or spreading
COVID-19 during an in-person event:
• Maintain a distance of at least 6 feet from people
you don’t live with – and be mindful in areas where
Several factors contribute to COVID-19 spreading in it may be harder to do so, such as restrooms and
group settings. Those include community spread of the eating areas.
coronavirus, event location, event duration, quantity • Wear a mask at all times when around people who
of attendees and the locations where attendees are don’t live in your household.
coming from. It’s also important to consider attendees’
• Limit contact with commonly touched surfaces or
behavior both prior to the gathering and during the
shared items.
celebration.
• Wash your hands often with soap and water. If
Before a Gathering
soap and water are not readily available, use a
If you choose to attend an in-person event, consider the hand sanitizer that contains at least 60% alcohol.
following tips prior to the gathering:
If you want to celebrate the holidays as safely as possible
• Check whether the host has steps in place to this year, consider celebrating virtually or with members
prevent the spread of the coronavirus. of your own household. n
• Bring along supplies likeMain
122 East extra masks,
Ave., tissues
Suite 201 and ND 58501
| Bismarck, | p 701.223.5303 | e angi@ndba.com
alcohol-based hand sanitizer.
24You can also read
