A publication for members of the North Dakota Bankers Association - February 25, 2022 Volume 22 Issue 2
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A publication for members of the North Dakota Bankers Association. Volume 22 • Issue 2 February 25, 2022 NDBA • PO Box 1438, Bismarck, ND 58502-1438 • Ph: 701.223.5303 • Fax: 701.258.0218 • Email: ndba@ndba.com • www.ndba.com
Registration Open Visit ndba.com. Opening New Accounts: Documentation and Compliance April 13, 2022 Hilton Garden Inn, Fargo Presenter: Suzie Jones April 14, 2022 Courtyard by Marriott, Bismarck March Upcoming NDBA Events 7-9 ABA Washington Summit - Washington DC and Virtually MARCH 2022 APRIL 2022 21 HSA Workshop - Virtual MAY 2022 S M T W T F S 22 IRA Essentials Seminar - Virtual S M T W T F S S M T W T F S 23 Advanced IRAs Seminar - Virtual 1 2 3 4 5 1 2 1 2 3 4 5 6 7 Mar 29- Dakota School of Lending Principles 6 7 8 9 10 11 12 3 4 5 6 7 8 9 8 9 10 11 12 13 14 April 2 Aberdeen SD 13 14 15 16 17 18 19 10 11 12 13 14 15 16 15 16 17 18 19 20 21 April 20 21 22 23 24 25 26 17 18 19 20 21 22 23 22 23 24 25 26 27 28 4-8 GSB HR Management School - Madison WI 27 28 29 30 24 25 26 27 28 29 30 29 30 31 13-14 Opening New Accounts Hilton Garden Inn, Fargo Courtyard by Marriott, Bismarck JUNE 2022 JULY 2022 AUGUST 2022 26-28 Tri-State Trust Conference - S M T W T F S S M T W T F S S M T W T F S Delta by Marriott, Fargo 1 2 3 4 1 2 1 2 3 4 5 6 June 5 6 7 8 9 10 11 3 4 5 6 7 8 9 7 8 9 10 11 12 13 5-10 Dakota School of Banking - University of Jamestown 12 13 14 15 16 17 18 10 11 12 13 14 15 16 14 15 16 17 18 19 20 14-15 NDBA/SDBA Annual Convention - 19 20 21 22 23 24 25 17 18 19 20 21 22 23 21 22 23 24 25 26 27 Bismarck 20-23 National School for Beginning Ag Bankers - 26 27 28 29 30 24 25 26 27 28 29 30 28 29 30 31 Black Hills State University, Spearfish SD 31 July SEPTEMBER 2022 OCTOBER 2022 NOVEMBER 2022 17-29 Graduate School of Banking at Colorado - Boulder CO S M T W T F S S M T W T F S S M T W T F S 1 2 3 1 1 2 3 4 5 July 31- Graduate School of Banking at Wisconsin - Aug 12 Madison WI 4 5 6 7 8 9 10 2 3 4 5 6 7 8 6 7 8 9 10 11 12 September 2022 11 12 13 14 15 16 17 9 10 11 12 13 14 15 13 14 15 16 17 18 19 12-15 Group Meetings - Grand Forks, Fargo, 18 19 20 21 22 23 24 16 17 18 19 20 21 22 20 21 22 23 24 25 26 Bismarck & Minot 25 26 27 28 29 30 23 24 25 26 27 28 29 27 28 29 30 October 2022 30 31 5-6 Ag Credit Conference - Delta Hotel by Marriott, Fargo 2
CoNTeNTS EXECUTIVE COMMITTEE FEBRUARY 2022 EDITION 20 CHAIR CHAIR-ELECT TREASURER LIVE WELL. WORK WELL. Christie Huber Obenauer Kathy Torske Pete Jahner MONTHLY HEALTH & WELLNESS NEWSLET TER Union State Bank Bravera Wealth Kirkwood Bank and Trust Hazen Bismarck Bismarck NDBA BOARD OF DIRECTORS Deneen Axtman Brian L. Johnson Brad Miller Cornerstone Bank Choice Bank First State Bank of Cando Fargo Grand Forks Cando 29 22 Judd Graham Lori Leingang Kim Settel Bremer Bank Bank of North Dakota Gate City Bank Fargo Bismarck Fargo FEATURES REDUCING YOUR STRESS DURING Take Charge of Your Stress AMERICAN HEART MONTH Todd Heilman Managing stress is good for your health and well-being.Taking steps to reduce your stress will improve your overall health. Try these tips: Jay Lies Lee Weisbeck According to the Centers for Disease Control and Prevention (CDC), heart Western State Bank • Simplify your schedule. If you’re feeling rushed or too busy, prioritize Choice Bank Starion Bank 12 Welcome New Associate Members disease is the leading cause of death in the United States. In fact, half of essential items on your calendar and to-do lists. all Americans are currently considered “at risk” for heart disease, and that Devils Lake Fargo Mandan figure continues to rise. Due to the prevalence of the disease, February • Practice relaxation techniques. Try listening to relaxing music to help is recognized as American Heart Month to raise awareness about heart you calm down or look into stress management or relaxation classes. disease and prevention. To celebrate, you can focus on dialing down your 16 From the Corner Chair stress level. Ryan Hertz • Get enough sleep. Adults should strive for seven to nine hours of quality sleep each night. Patrick Lorenson Stress and Heart Health While there are risk factors that contribute to heart disease that you can’t Dacotah Bank • Exercise regularly. Movement can get your blood and endorphins Ramsey National Bank control, there are many things you can do to maintain your heart health. Minot flowing, relieving stress, tension, anxiety and depression. Fargo 20 Bankers Enjoy Sunshine and Excellent Content at One of those things is to reduce your stress. Having too much stress for too long is bad for your heart. • Maintain social connections. It’s important to make time for friends and family and talk with people you trust. the Bank Management Conference If the stresses in your life become more than you can bear or manage with these techniques, consider seeking professional assistance. NDBA SERVICES, INC. BOARD OF DIRECTORS 22 Live Well. Work Well. Some people may handle their stress with poor health behaviors—such as . CHAIR smoking, eating unhealthy foods and drinking alcohol. Such behaviors can Jeremy Skoglund Jeff Weiler put you at an increased risk for heart disease and stroke. Lori Kubitz 25 Tri-State Trust Speaker Lineup Zywave, 2022. This article is intended for informational purposes only and is not intended to be exhaustive, nor should any discussion or opinions be construed as professional advice. Readers should contact a health professional for appropriate advice. © 2021 Zywave, Inc. All rights reserved. Bank of North Dakota First Western Bank & Trust Bank of North Dakota Bismarck Fargo Bismarck 29 Convention Featured Speaker: Kat Perkins VICE-CHAIR Jona Ziemann Jamie Nelson 36 Public Pension Update Kelly Hoeven McLean Bank Holding Co. Starion Bank The Union Bank of Glen Ullin Garrison Mandan Glen Ullin 40 Retirement Enhancements Expected in 2022 BOARD LIAISONS Cayle Paulson Legislative Proposals Lois Bednar Dakota Heritage Bank Pete Jahner Bank Forward Harvey Kirkwood Bank and Trust Fargo Bismarck Bernie Sinner IN EVERY ISSUE Duane Bowman BankNorth Kathy Torske Dakota Western Bank Casselton Bravera Wealth 2 Calendar of Events Bowman Bismarck 3 NDBA Directors & Staff 4 Articles NDBA STAFF Rick Clayburgh Lisa Dolajak Ann Reich 14 NDBA Education Events & Webinars President and CEO Communications and SVP of Strategic Partnerships rick@ndba.com Marketing Coordinator ann@ndba.com 44 Happenings Jackie Bauer lisa@ndba.com Business and Database Jolene German NDBA GENERAL 46 Banker Classifieds Coordinator Administrative Assistant COUNSEL jackie@ndba.com jolene@ndba.com Tracy Kennedy Angi Day Dorothy Lick tracy@ndba.com Mission Statement Benefits Coordinator angi@ndba.com SVP of Education dorothy@ndba.com Extraordinary Leadership for North Dakota Banks 3
BANKING ARTICLES Biden Administration Announces FHFA Re-Proposes Updated ‘Unprecedented’ Sanctions Seller, Servicer Eligibility against Russia Requirements In response to the invasion of Ukraine by Russian troops, The Federal Housing Finance Agency have re-proposed updated President Biden announced a second round of economic standards that mortgage lenders would have to meet in order sanctions, including those against two additional large Russian to sell loans to or service loans on behalf of Fannie Mae and financial institutions, Sberbank and VTB Bank. Freddie Mac. The proposed update includes requirements for the servicing of Ginnie Mae mortgages. FHFA also noted that in this In a statement, the Treasury Department said that within 30 latest proposal, it has also incorporated feedback from a January days, the Office of Foreign Assets Control will require all U.S. 2020 proposal, as well as lessons learned from the COVID-19 banks “to close any Sberbank correspondent or payable-through pandemic. accounts and to reject any future transactions involving Sberbank or its foreign financial institution subsidiaries. Payments that Under the proposed requirements, all sellers and servicers would Sberbank attempts to process in U.S. dollars for its clients – with be required to maintain a base net worth of $2.5 million plus examples ranging from to technology to transportation – will 35 basis points of the unpaid principal balance for Ginnie Mae be disrupted and rejected once the payment hits a U.S. financial servicing and 25 basis points of the unpaid principal balance for institution.” all other 1-to-4-family loans serviced. Depository institutions would continue to rely on their prudential regulatory standards to OFAC will also impose full blocking sanctions on VTB Bank – a meet the GSEs’ capital and liquidity requirements. systemically important institution that holds nearly 20% of all banking assets in Russia – and will immediately freeze all assets Among other things, nonbanks’ minimum capital ratio would held in U.S. financial institutions. The sanctions also extend to 20 remain unchanged, while their minimum liquidity would rise VTB Bank subsidiaries. from 3.5 basis points of their total agency servicing to four basis points for GSE servicing and 10 basis points for Ginnie Mae Additionally, OFAC will block three additional Russian banks servicing. Comments on the proposed changes will be due in 60 – Otkritie, Novikom and Sovcom – from accessing the U.S. days. financial system. Treasury also announced additional debt and equity prohibitions against 13 other state and private-owned Read more: https://www.fhfa.gov/Media/PublicAffairs/ firms operating in the financial services sector, as well as a series Documents/SE2-Proposal-FAQ.pdf of actions targeting several Russian families with close ties to President Putin. IRS Releases Proposed Required Separately, OFAC also sanctioned 24 Belarusian individuals Minimum Distribution Rule and entities for their support for and facilitation of the Russian invasion. The IRS released its proposed required minimum distribution rule for retirement plans and IRAs, implementing Sections 114 Read more: https://www.whitehouse.gov/briefing-room/ and 401 of the bipartisan Secure Act of 2019. The proposed statements-releases/2022/02/24/fact-sheet-joined-by-allies-and- rule affects administrators, participants, owners, beneficiaries partners-the-united-states-imposes-devastating-costs-on-russia/ 4
aRTiCLeS of plans and IRAs, as well as addresses the act’s requirements The next step, the bureau said, is to review the options to for designated beneficiaries, trusts as plan and IRA beneficiaries determine their potential impact on small banks and businesses including multi-beneficiary trusts, see-through trusts and conduit through initiation of the Small Business Regulatory Enforcement trusts. Comments will be due on May 25. Review Act review process required for all CFPB rulemakings. Read more: https://www.federalregister.gov/ Read more: https://files.consumerfinance.gov/f/documents/cfpb_ documents/2022/02/24/2022-02522/required-minimum- avm_outline-of-proposals_2022-02.pdf distributions CFPB Issues Factsheet on CFPB Zeroes in on Auto Lending Calculating Interest for ARMs to Market Satisfy QM Definition In a new blog post, the CFPB signaled that it intends to increase The CFPB has released a factsheet on calculating prepaid interest its focus on the auto lending market. The bureau noted that on “short-reset” adjustable-rate mortgages and step-rate loans. prices for new and used cars have increased significantly over the The bureau's price-based General Qualified Mortgage definition last year, and that “we expect that both the total amount of debt contains a special rule for calculating annual percentage rates on and the average loan size will continue to increase and that larger these kinds of loans where the interest rate may or will change car loans will put increased pressure on some consumers’ budgets within five years of the first regular periodic payment due date. for much of the next decade.” Read more: https://files.consumerfinance.gov/f/documents/cfpb_ Among other things, the CFPB expressed concern about loan- atrqm_prepaidinterest_factsheet.pdf to-value ratios in the auto lending market, auto loan servicing and collections practices and the subprime auto lending market in particular. “We are looking to better understand potential Republican Lawmakers Call for barriers to competition in the subprime auto lending market that Changes to CFPB’s Section 1071 may drive these and related outcomes,” the bureau said. “We will continue to research auto lending policies and practices that may Proposal hinder a fair, transparent, and competitive market. And, we will Three GOP lawmakers are raising concerns about the CFPB’s work with our counterparts at the Federal Trade Commission and pending rulemaking to implement Section 1071 of the Dodd- the Federal Reserve Bank Board of Governors to use our collective Frank Act. Citing concerns received from industry stakeholders, authorities to address issues in the market.” including banks of all sizes, Reps. Blaine Luetkemeyer (R-Mo.), French Hill (R-Ark.) and Roger Williams (R-Texas) flagged Read more: https://www.consumerfinance.gov/about-us/blog/ several issues and called on the CFPB to remedy these issues rising-car-prices-means-more-auto-loan-debt/ within the final rulemaking. CFPB Outlines Automated In particular, the lawmakers expressed concerns about the potential effects of the rule on small banks and urged the CFPB Valuation Model Rulemaking “to exclude as many small financial firms as possible,” and also Proposals called for a longer implementation period, given the complexity of the rule. The CFPB has announced the next step in a joint agency rulemaking to develop quality control standards for the use of The lawmakers also took issue with a provision of the proposed computer models, known as automated valuation models, used to rule that would require financial institutions to guess the race of help assess home valuations. applicants who choose not to provide their information. “Loan officers at financial institutions have no expertise to determine the The Dodd-Frank Act requires the bureau, the federal banking race or ethnicity of individuals, nor should they,” the lawmakers agencies, NCUA and the Federal Housing Finance Agency to write wrote, calling for the removal of the provision. Finally, they a rule to strengthen oversight of the models to “ensure a high level emphasized that the CFPB “must fully disclose what information of confidence in the estimates; protect against the manipulation of will become public before the final rule is issued and must data; avoid conflicts of interest and require random sample testing conduct a separate rulemaking process, including notice and and reviews.” The CFPB said the computer models and algorithms comment, related to this provision of the law.” improve valuation accuracy for mortgage lenders and appraisers, but the bureau is concerned that automated valuation models can Read more: http://www.ndba.com/uploads/23/ pose fair-lending risks to buyers and sellers. GOP1071Letter02162022.pdf 5
aRTiCLeS Crypto Assets Could be Threat to The Federal Reserve has not had an adequate supply of coin to meet financial institution demand and has begun rationing coin Global Financial Stability allocations as a result. The crypto-asset market could reach a point where it presents The Federal Reserve and the U.S. Mint will use the paper as a threat to global financial stability, according to a new report they work with a third-party consultant to review the coin released by the Basel, Switzerland-based Financial Stability Board. supply chain and develop recommendations to improve it. In The fast-evolving nature of crypto assets, scale, as well as the meantime, the task force continues to encourage consumers structural vulnerabilities and “increasing interconnectedness” to keep coins circulating by spending, depositing, exchanging with the traditional financial system could threaten global or donating them, financial institutions to deposit excess coin financial stability, the FSB warned. The international nature inventory and retailers to accept and recirculate coins at their tills. of crypto markets “also raise the potential for regulatory gaps, Read more: https://getcoinmoving.org/media/020922-state-of- fragmentation or arbitrage,” according to the report. coin-paper.pdf While the nature and use of crypto assets varies across jurisdictions, financial stability risks could rapidly escalate, Treasury Opens CDFI Fund the FSB said in the report, adding that there is a need for an evaluation of possible policy responses. Applications for 2022 The Treasury Department opened the 2022 fiscal year funding The FSB acknowledged there are significant data gaps impeding round for the CDFI program and the Native American CDFI risk assessments of crypto assets, due to trading and lending assistance program, which help provide affordable financing platforms falling outside of regulatory boundaries and reporting to low-income communities and populations that lack access requirements. The FSB also warned that crypto asset participants, to credit. For fiscal year 2022, pending final congressional products and markets “may be failing to comply with applicable appropriations, the CDFI Fund will make up to $204 million in laws and regulations.” awards. Read more: https://www.fsb.org/2022/02/fsb-warns-of-emerging- Read more: https://www.cdfifund.gov/news/439 risks-from-crypto-assets-to-global-financial-stability/ OCC Issues FAQs on Final Rule to Regulators Hosting Virtual Rescind 2020 CRA Regulations Community Reinvestment The OCC issued a set of frequently asked questions on its final Conference rule to rescind its 2020 Community Reinvestment Act rule and On March 15-17, the federal banking regulatory agencies replace it with rules based on the 1995 CRA rules that were will host the 2022 virtual National Interagency Community jointly adopted by the OCC, Federal Reserve and FDIC. Reinvestment Conference. The biennial conference offers participants the opportunity to learn about the CRA, participate The FAQs address qualifying activities, transition period, in regulator-led training on CRA examinations and discuss examination administration, assessment areas, targeted geographic best practices, emerging ideas, and challenges in community areas, data reporting, changes to public notices and strategic development. plans. Read more: https://web.cvent.com/event/f3a7f84b-9727-42d6- Read more: https://occ.gov/news-issuances/bulletins/2022/ a69c-ba4a85b06a3d/summary?RefId=frb-web bulletin-2022-4.html Coin Task Force Issues Paper on CFPB Allows Consumers to Coin Circulation Slowdown Directly Petition for Rulemakings The CFPB has announced a new process through which The U.S. Coin Task Force has released a new paper on the state of consumers may petition the bureau directly for rulemaking the coin supply chain in the U.S. and the causes and effects of the actions. All petitions and related materials submitted will become coin circulation disruption that occurred during the COVID-19 part of public record and will be subject to public disclosure, and pandemic. The paper identifies the factors that contributed to the the CFPB will respond to petitions for the issuance, amendment coin circulation disruption, including a significant drop in coin or repeal of an existing rule as required by the Administrative deposits since the outset of the pandemic, a reduction in new coin Procedures Act. production at the U.S. Mint in the early days of the pandemic. 6
aRTiCLeS Consumers may email their petitions to petitions@cfpb.gov or highest individual median losses at $9,000, compared to $750 for submit them to the bureau by mail or hand delivery. Petitions victims between ages 18 and 29. should include contact information, the type of action being Read more: https://www.ftc.gov/news-events/blogs/data- requested, the factual and legal reasons for the proposed action spotlight/2022/02/reports-romance-scams-hit-record-highs-2021 and the expected effects the proposed action would have on relevant parties. DOL Seeks Input on Climate- In its press release, the bureau added that “[f ]ormer government employees and other individuals who are paid to influence the Related Financial Risks for agency’s rulemaking agenda behind the scenes will be asked to Retirement Plans submit their petition for public inspection instead.” The Department of Labor has filed a request for information Read more: https://www.consumerfinance.gov/rules-policy/ seeking public input on its forthcoming work on retirement petitions-rulemaking/ savings and climate-related financial risks. The request is intended to assist the department in identifying steps it can take “to further Federal Banking Regulators Urge protect the life savings and pensions of U.S. workers and families from the threat of climate-related financial risk.” The RFI stems SPCP Use from an executive order directing DOL to ensure the resilience of The federal banking regulators are reminding banks and creditors retirement savings through regulatory action. of the ability under the Equal Credit Opportunity Act and Among the questions for public comment, the RFI asks how Regulation B to establish special purpose credit programs to DOL should address the protection of retirement savings from meet the credit needs of specified classes of persons. SPCPs are climate-related financial risks, as well as what data should programs designed to direct financial assistance to groups who be collected from plan sponsors, administrators and service have historically been hindered from homeownership. The providers. regulators said they encourage creditors to explore opportunities to develop SPCPs. Other questions DOL is seeking information on include whether the annual reporting Form 5500 or other form or method should Read more: https://www.fdic.gov/news/financial-institution- be used to collect the data, whether plan administrators should be letters/2022/fil22008.html required to publicly report the steps they take to manage climate- related financial risks and the results and outcomes of any such Romance Scam Losses Hit Record steps taken. The deadline for comments is May 15. High in 2021 Read more: https://www.federalregister.gov/ Romance scams are on the rise, with consumers losing $547 documents/2022/02/14/2022-02798/request-for-information-on- million to them in 2021 alone, according to new data published possible-agency-actions-to-protect-life-savings-and-pensions-from- by the Federal Trade Commission. That figure was up 80% from threats $307 million in 2020. The median individual loss reported in 2021 was $2,400. Household Debt Rises by $333 The FTC also found that cryptocurrency payments related to Billion in Fourth Quarter of 2021 romance scams are growing – in 2021, $139 million in losses Total household debt increased 2.2% in the fourth quarter of reported due to romance scams were paid in cryptocurrency – 2021, rising by $333 billion to land at $15.58 trillion, the Federal nearly five times higher than in 2020 and more than 25 times Reserve Bank of New York reported. Mortgage balances, the higher than those reported in 2019. The median individual loss largest component of household debt, rose by $258 billion in the reported among those who made cryptocurrency payments was fourth quarter to reach $10.93 trillion. Among non-mortgage $9,770. The FTC noted, however, that gift cards are the most debt categories, credit card balances increased by $52 billion common method of payment in romance scams – about one in in the fourth quarter, the largest quarterly increase on record. four romance scam victims said they paid with a gift card. Student loans contracted by $8 billion from the prior quarter. In The data also showed that romance scams were up across all age total, non-housing balances grew by $74 billion. groups, though the increase was most striking for people ages As of late December, 2.7% of outstanding debt was in some stage 18 to 29, which saw a tenfold increase between 2017 and 2021. of delinquency, a two percentage point decline from the fourth However, older victims – those 70 and older – reported the quarter of 2019, just before the COVID-19 pandemic hit the 7
aRTiCLeS U.S. The share of mortgage balances delinquent 90 days or more CFPB to Scrutinize Credit Card held at 0.5% in the fourth quarter, a historic low. Fees, Practices For auto loans and credit card debt, the share flowing into 90- day delinquency declined to 1.6% for auto loans and declined In a blog post, the CFPB said it is “looking to use a long- to 3.2% for credit card debt. The rate of serious student loan dormant authority” under Dodd-Frank Act Section 1033, delinquency was 5%, which reflected a Department of Education which relates to consumer access to financial records, “to help decision to report current status on loans eligible for CARES Act spur better credit card shopping and switching by proposing forbearances. rules that give consumers more control of their financial data.” The bureau noted that it plans to focus on uncovering “unfair, Read more: https://www.newyorkfed.org/microeconomics/hhdc. anticompetitive practices,” making it simpler for consumers to html compare, switch or refinance their credit card and scrutinizing fees associated with credit card offerings. CFPB Issues Compliance Bulletin Consumers paid roughly $117 billion in interest and fees in on Use of Prepaid Cards for 2020, according to the blog post. That figure was down from Government Benefits $128 billion in 2019 and $119 billion in 2018. The CFPB also acknowledged in a previous report issued during former Acting The CFPB has released a compliance bulletin reiterating Director Dave Uejio’s tenure that “credit cards played a vital role” that the Electronic Fund Transfer Act and its implementing to consumers during the COVID-19 pandemic. regulation, Regulation E, apply to government benefits accounts Read more: https://www.consumerfinance.gov/about-us/blog/ with the exception of state and local electronic benefit transfer programs. In addition to summarizing the regulation’s disclosure americans-pay-120-billion-in-credit-card-interest-and-fees-each-year/ requirements for government benefit accounts, the bulletin noted that Regulation E prohibits a person from requiring a consumer Federal Court Upholds OCC, to establish an account to receive electronic fund transfers with FDIC’s ‘Valid-When-Made’ Rules a particular financial institution as a condition of receipt of a government benefit. A federal district court has upheld the OCC’s and FDIC’s “valid- when-made” rules, in separate rulings. The agencies’ rules had While the CFPB’s press release announcing the bulletin’s affirmed that permissible interest on a loan made by a national or publication referenced fees associated with government benefits, state-chartered bank or federal thrift remains valid when the loan neither the bulletin nor the regulation address fees associated with is transferred or sold. After the OCC and FDIC issued separate government benefits accounts. rules in 2020, several state attorneys general challenged both rules Read more: https://files.consumerfinance.gov/f/documents/cfpb_ in court. bulletin-2022-02_electronic-fund-transfer-act_2022-02.pdf The agencies’ so-called “Madden fix” rules responded to a Second Circuit Court of Appeals ruling in Madden v. Midland Funding, Fed Releases Synthetic ID Fraud which held that a nonbank buyer of a loan issued by a national Mitigation Toolkit bank could not export the originated interest rate into another state. As instances of synthetic identity fraud – through which fraudsters create new identities out of pieces of real or fictitious OCC Acting Comptroller Michael Hsu welcomed the district information – become more prevalent, the Federal Reserve court’s ruling on the OCC’s rule, but cautioned that the “legal has released a toolkit to help banks and consumers mitigate certainty” provided by the valid-when-made rule “should be risks associated with this type of fraud. The toolkit includes used to the benefit of consumers and not be abused.” Hsu also downloadable resources explaining the basics of synthetic identity reiterated that “predatory lending has no place in the federal fraud, how fraudsters use synthetic identities and how to identify banking system” and that the OCC is committed to ensuring synthetic identities. The Fed said it will add new resources to the “banks are not used as a vehicle for ‘rent-a-charter’ arrangements.” toolkit in the future, including more on synthetic identity fraud detection and mitigation. FDIC’s Gruenberg Shifts Agency’s Read more: https://fedpaymentsimprovement.org/synthetic- 2022 Priorities identity-fraud-mitigation-toolkit/ Following the departure of Jelena McWilliams from the FDIC, Acting Chairman Martin Gruenberg outlined his agency’s shift 8
aRTiCLeS in priorities for the year ahead. Gruenberg identified five primary income communities. Hsu added that he believes it is important focus areas for the FDIC in 2022: “strengthening and enhancing” to increase the “clarity, consistency and transparency” of CRA the Community Reinvestment Act through an interagency supervisory expectations and standards regarding activities process; addressing the financial risks posed by climate change; that are eligible for CRA credit and how eligible activities are reviewing the bank merger process, which according to evaluated. He also noted that CRA standards should be updated Gruenberg hasn’t been addressed in 25 years; evaluating crypto- to reflect “changes in the business of banking,” in particular the asset risk to determine the extent to which banking organizations increased use of mobile and internet delivery channels. can safely engage in crypto-asset-related activities; and Read more: https://www.occ.gov/news-issuances/speeches/2022/ implementing the capital framework commonly known as “Basel pub-speech-2022-15.pdf IV,” which was delayed due to the pandemic. “While there are many pressing issues the FDIC will have to PPP Borrowers May Request address this year,” he said, these priorities “will require close collaboration among the federal banking agencies.” Review of Partially Forgiven With respect to climate change, Gruenberg said the agency Loans will seek “public comment on guidance designed to help banks The SBA announced that it will allow Paycheck Protection prudently manage these risks, [establish] an FDIC interdivisional, Program borrowers to request a loan review by SBA when the interdisciplinary working group on climate-related financial lender determines that the borrower is entitled to only partial risks, and [join] the international Network of Central Banks and forgiveness of the PPP loan. Under a procedural notice issued by Supervisors for Greening the Financial System.” SBA, when a lender receives a forgiveness remittance from SBA Read more: https://www.fdic.gov/news/press-releases/2022/ on a loan where only a portion of the PPP loan was forgiven, pr22015.html the lender must inform the borrower that it has 30 calendar days to seek, through the lender, an SBA loan review of the lender’s partial approval decision. SBA retains discretion to accept or FASB Rejects Further CECL Delays deny the borrower’s request to review the loan. If SBA selects the The Financial Accounting Standards Board has rejected a proposal loan for review, the loan is not deferred and the borrower must to delay the current expected credit loss (CECL) accounting continue to make payments on the remaining balance of the loan. standard for those banks that have yet to adopt it. Therefore, SBA also advised that by Feb. 26, lenders must notify all of their CECL will become effective for smaller SEC registrants and borrowers of loans that previously received a partial forgiveness private companies on January 1, 2023. During its meeting, decision that the borrower has 30 calendar days to seek, through FASB board members also expressed support for simplified the lender, an SBA loan review of the lender’s partial forgiveness methodologies, including the Federal Reserve Board’s “SCALE” decision. methodology. SCALE, which largely relies on peer allowance coverage ratios, was introduced by the Fed to make CECL SBA advised that it will be providing lenders with additional scalable for community banks. guidance through the platform, including step-by-step instructions. Acting Comptroller Indicates Read more: https://www.sba.gov/document/procedural-notice- Agencies Will Issue CRA NPR 5000-827666-sba-loan-reviews-paycheck-protection-program-lender- partial-approval-forgiveness-decisions Soon In public remarks, Acting Comptroller of the Currency Michael OCC Issues Bulletin on Hsu indicated that he expects the OCC, FDIC and the Federal Considering State Community Reserve will issue a proposal to update and modernize the Community Reinvestment Act (CRA) regulations in the “not- Reinvestment Law Complaints too-distant future.” The Fed’s 2020 advance notice of proposed The OCC has issued a bulletin outlining its processes for rulemaking (NPR) on CRA modernization is serving as the basic considering input from state banking commissioners regarding framework for the interagency conversations about the proposal. national banks’ performance under state community reinvestment He also noted that the revised regulations will help increase levels laws, including implementation of community reinvestment- of CRA activity to help address existing disparities and ensure that related provisions of the Riegle-Neal Act. (The OCC noted that banks are being responsive the local needs of low- and moderate- Riegle-Neal does not apply to federal savings associations.) The 9
aRTiCLeS bulletin also addresses expectations regarding the handling of IRS Releases FAQs to Help consumer complaints that state officials refer to national banks and federal savings associations, as well as state referrals of Taxpayers Prepare 2021 Returns complaints to the OCC. The Internal Revenue Service has published a series of frequently The bulletin, which rescinds two previous advisory letters, asked questions to assist taxpayers who received the advance outlines OCC policies and procedures in these areas, provides child tax credit or who were eligible to receive the child tax credit an email address for state banking commissioners to submit in preparing their 2021 tax returns. The FAQs address child input to the OCC, provides general guidance for banks on tax credit basics, eligibility rules for claiming the tax credit and handling consumer complaints that state officials refer to banks commonly asked immigration-related questions. and provides updated mailing addresses for the OCC’s customer Read more: https://www.irs.gov/newsroom/irs-issues-2021-filing- assistance group and the OCC’s chief counsel’s office. season-frequently-asked-questions-information-to-help-taxpayers- Read more: https://occ.gov/news-issuances/bulletins/2022/ preparing-their-2021-returns bulletin-2022-2.html FOMC to End Asset Purchases by CFPB Probes for Information on Early March Financial Product Fees The Federal Reserve will continue to reduce the monthly pace The CFPB has issued a request for information seeking comments of asset purchases and bring them to an end in early March, on fees associated with financial products and services offered by according to the latest Federal Open Market Committee banks and non-bank financial institutions, including overdraft statement. Fed Chairman Jerome Powell said inflation remains fees, insufficient funds fees, credit card fees, remittance fees, well above the Fed's longer-run goal of 2% and that supply and prepaid account fees and mortgage fees, among others. demand imbalances related to the pandemic and the reopening of the economy have continued to contribute to elevated levels of The bureau said it would use the feedback received from the inflation. RFI to “assist the CFPB and policymakers in exercising its enforcement, supervision, regulatory and other authorities In a press conference after the release of the FOMC statement, to create fairer, more transparent and competitive consumer Powell said he does not expect supply chain issues to be financial markets.” completely worked out by the end of this year but does expect progress to be made in the second half of the year. A joint statement by seven financial trade groups, called the CFPB’s effort “misguided,” noting that it paints a “distorted and The committee also said it would continue to hold the target misleading picture” of the nation’s financial services marketplace. range for the federal funds rate at its current level of zero to “Multiple federal laws and the CFPB's own rules already require 0.25%, but noted that they expect “it will soon be appropriate banks, credit unions and other providers of consumer financial to raise the target range for the federal funds rate.” The FOMC services to disclose terms and fees in a clear and conspicuous reiterated that the path of the economy continues to depend on manner, and our members do so each and every day,” the groups the course of COVID-19. The statement added that indicators of said. “Consumers in this country know they have a wide range of economic activity and employment have continued to strengthen choices when it comes to financial services products, and those and the sectors most adversely affected by the pandemic have businesses compete every day, including on fees. We look forward improved in recent months but are now being affected by the to responding to this request for information with facts and recent sharp rise in COVID-19 cases. perspective sadly lacking from today's announcement.” The Fed also issued principles for how it plans to unwind its Comments on the RFI will be due March 31. balance sheet, and reaffirmed its longstanding statement on its longer-run monetary policy goals, which target an inflation rate Read more: https://files.consumerfinance.gov/f/documents/cfpb_ of 2%. avm_outline-of-proposals_2022-02.pdf Read more: https://www.federalreserve.gov/newsevents/ pressreleases/monetary20220126a.htm 10
aRTiCLeS Fed Releases Report on US services, the survey found, with 29% saying that they expect to add these services within the next 18 months. Central Bank Digital Currency A top concern for community banks was talent management, The Federal Reserve has released a report that details the potential the survey found, with 74% rating it as a primary concern. benefits and risks of creating a US central bank digital currency Nearly half said a labor shortage is a factor in talent management (CBDC). The Fed’s report did not take a position on creating a and 67% said they are “extremely concerned” about employee CBDC; however, the Fed did indicate that it “will continue to retention and recruitment. explore a wide range of design options.” Read more: https://www.wipfli.com/-/media/wipfli/downloadable- The report notes that a CBDC “would best serve the needs of the files/FI-State-of-Community-Banking-2022-Outlook.pdf United States by being privacy-protected, intermediated, widely transferable and identity-verified.” An intermediated model through which the private sector would facilitate the management CFPB Report Finds Banks of CBDC holdings and payments through accounts or digital Providing Most Public D&I wallets is one of the potential structures the Fed has considered Information of Financial Services and the report states that such a model “would facilitate the use of the private sector’s existing privacy and identity-management Firms frameworks; leverage the private sector’s ability to innovate; and In a report issued by the CFPB’s Office of Minority and Women reduce the prospects for destabilizing disruptions to the well- Inclusion, the agency found that banks and other depository functioning US financial system.” institutions have the highest amount of publicly available However, the agency did acknowledge that a CBDC could, information about diversity and inclusion in the financial services depending on its design, “fundamentally change the structure sector. The report also found that few organizations in financial of the US financial system, altering the roles and responsibilities services besides banks had either a dedicated diversity and of the private sector and the central bank.” Ultimately, the Fed inclusion executive or any formal body directing DEI initiatives. concluded that it “does not intend to proceed with the issuance In addition, the CFPB noted that banks had the most supplier of a CBDC without clear support from the executive branch diversity in the financial services sector with nearly 60 percent and from Congress, ideally in the form of a specific authorizing of institutions surveyed having minority and women-owned law.” The paper also requests public feedback on these topics and business programs. The Bureau also found that almost half of comments will be accepted until May 20. sampled banks published information on their diversity and Read more: https://www.federalreserve.gov/publications/files/ inclusion strategic plans. money-and-payments-20220120.pdf The CFPB plans to use the data collected as part of the report to provide examples of diversity and inclusion best practices, Community Banks Keeping resources, and peer success stories to financial institutions. Branches Open Read more: https://files.consumerfinance.gov/f/documents/cfpb_ diversity-inclusion-within-financial-services_report_2022-01.pdf Community banks are keeping bank branches open, with 84% responding to a recent survey that they have not closed a single branch in the past 12 months. The State of Community Banking survey issued by consulting firm Wipfli also found that 32% of community banks have their farthest branches 10-20 miles from their headquarters and 23% have their farthest branches more than 41 miles away from their headquarters. The survey of 177 community banks in 33 states also found that community banks are increasing the services they offer, with 77% responding that they have added wealth advisory services in the past three years. Fifty-six percent of banks responded that they have added trust services in the last three years and the same percent said that they have added insurance services in that time. Community banks are also exploring adding cryptocurrency 11
Welcome NDBA’s New Associate Members Keenan & Partners Superior IRA & HSA, LLC Contact: Tom Keenan Contact: Jason Bain 4916 SE Hill Rd 44121 365th St Portland, OR 97267-1701 Ottertail, MN 56571-9476 Keenan & Partners is a business partner specializing in Superior IRA & HSA, LLC is revolutionizing the landscape the repositioning of branch and admin facility real estate of IRA and HSA programs, bringing industry veterans for community banks. Specialized services offered include: with decades of deep compliance expertise together with a Branch footprint cost benefit analyses, valuation and sale cutting edge fintech platform. of Facilities Real Estate, existing lease analysis and exit Superior’s software platform is built from the ground up negotiations, branch de novo: new site analysis, selection, to provide unprecedented simplicity and efficiency for and acquisition negotiation, administrative facility and back your branch staff, providing peace of mind with the best office square footage analysis and needs review, excess land compliance support available. Our cloud-based solution and facility sales, sale/leaseback exit strategies, deposit sales offers scale and open API connectivity on an unprecedented strategies, and shrink in place strategies for the downsizing level. Our technology upgrades your bank’s ability to of existing branch spaces. Founded in 2010, Keenan & create and assign custom user roles for more efficient and Partners has completed more than 200 branch valuation and compliant branch-level operations and creates an improved repositioning assignments for its community banking clients customer experience. since 2014. Superior raises the bar even further by offering modernized compliance support in formats that do not currently exist with other providers. We have created additional technical support options by adding live, online chat and email to the traditional phone support that is offered by other providers. Exceptional service. Today’s technology. Superior results. NDBA encourages member banks to utilize the products and services provided by NDBA Associate Members. Each Associate Member is approved by the NDBA Board of Directors. If you should have any questions or would like more information on the North Dakota Bankers Association’s Associate Members, please contact Ann Reich at 701.223.5303 or ann@ndba.com. 12
CONSULTING | NETWORK SECURITY | IT AUDIT | EDUCATION Rick Olivier | rick.olivier@sbscyber.com 605-270-3321 (call or text) 13
North 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? HSA Frontline March 21 Virtual via Zoom Attend the HSA Seminar for practical understanding of critical rules and operational Fundamentals issues of a successful HSA program. IRA Essentials March 22 Virtual via Zoom The IRA seminar will cover basic rules of IRAs and serve as a refresher on IRA rules and operations. Advanced IRAs March 23 Virtual via Zoom The Advanced IRA seminar will build on attendees’ basic IRA knowledge to address some of the more complex IRA issues that banks may handle. Previous IRA knowledge is assumed. Dakota School of March 29-April 1 Aberdeen SD Loan officer trainees, loan support personnel and personal bankers. Lending Principles Opening New April 13 Hilton Garden Inn, Fargo All customer contact personnel, supervisors and Accounts: April 14 Courtyard by Marriott, Bismarck officers whose responsibilities include opening or managing new accounts and certificates of Documentation & deposit. Compliance Tri-State Trust April 26-28 Delta Hotel by Marriott Trust officers, trust attorneys, CTFAs, and CFPS. Conference Fargo ND Dakota School of June 5-10 University of Jamestown, Attendees are generally first-or mid-level Jamestown ND managers seeking advancement in their banks Banking and careers. 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. NDBA/SDBA Annual June 14-15, 2022 Bismarck ND Presidents, CEOs, senior management staff, lenders, marketing team members and sales Convention managers. 14
Upcoming Bank Webinars NDBA offers convenient bank training and access to timely topics through a variety of webinars. EVENT DATE EVENT DATE Loan Denials & Other Adverse March 1 Opening New Accounts Part III: March 11 Action Notices Trust and Fiduciary BSA Emerging Issues March 1 Residential Construction March 14 Lending Opening New Accounts Part I: March 2 Personal/Consumer Accounts Responsibilities of the March 15 Information Security Officer Opening New Accounts - 3-Part March 2 Series Regulation CC - Annual Staff March 15 Training Consumer Real Estate Loans March 2 Wire Transfer Compliance March 16 IRA Reporting - Annual Update March 3 CRA - Review and Update March 16 A Passion for Women in March 3 Leadership - Encouraging the Writing New Account March 17 Next Generation of Women Procedures Leaders Regulation B: The Equal Credit March 17 CECL in the Call Report March 4 Opportunity Act Work Appearance, Dress Codes March 7 Ransomware, Phishing, March 18 and Employer's Liability for Business Email Compromise, Being Out of Fashion Oh my! Is Your Incident Response Plan Ready The Four Cs of Exceptional March 8 Supervision Understanding the Basics of March 21 Cryptocurrency Including Red The UCC for Lenders March 8 Flags Escrows March 9 For more information, visit www.ndba.com and Basic Excel Skills for March 9 click on “Education” and then “Web Seminars.” Accountants IRA Beneficiary Payout Options March 10 Opening New Accounts Part II: March 10 Business Accounts 15
From the CORNER CHAIR Christie Huber Obenauer | NDBA CHAIR | Union State Bank, Hazen You know how it feels when you have been gone for a couple of days, and you return to your office decorated with piles of mail, a fresh tsunami of emails, and a line of people at your office door? And you love them, and it, and your purpose, and your quickly-fading tan on your face, but you wonder inside of yourself why you ever try to leave the office for more than one day…..ever? Yeah. I have a feeling that you are intimately familiar with this feeling, and I am so there right now. But for those of you who joined me at the Bank Management Conference in Scottsdale last week, I bet you also still have a smile on that tanned face remembering how great it was to reconnect with everyone, and find new inspiration and renewed drive from our incredible speakers, and from conversations with friends and colleagues you have missed seeing – and from meeting new faces of people who are in our sandbox with us. It was fantastic, actually. This is my opportunity to shout out a big THANK YOU to our NDBA staff for organizing a truly incredible conference, at a truly incredible space, where we were reminded in all the best ways why we do what we do, and why we do it together. Thank you to our Past Chairs who joined us for dinner. As I said that night, you blazed the trails before us and we are doing our best to carry that torch forward and continue your legacy of innovation, and servant-hearted leadership. Thank you also to our partners who joined us – American Bankers Association, Arctic Wolf Networks, Ascensus, The Baker Group, Bell Bank, BHG Bank Group, Colliers Securities, D.A.Davidson & Co., Dakota Carrier Network, Graduate School of Banking - Wisconsin, IntraFi Network, MBIS, NDBA Services, Raymond James, SBS Cybersecurity, SHAZAM, and UMB Bank. We know that collaboration and partnership is what it is going to take to succeed in this industry that is metamorphosing as quickly as we can pivot. We have more opportunities to gather in the next couple of months. I am so looking forward to those opportunities. Be sure to check the Events Calendar (page 2), and take a moment to look at the pictures of your fellow community bankers who gathered in this past month. Each of you inspire me to lean in, and continue to shape the future we are navigating toward. Onward! 16
SDBA/NDBA Registration now at sdba.com 2022 Dakota School of Lending Principles March 29 - April 1, 2022 | Best Western Ramkota Hotel, Aberdeen, S.D. The SDBA/NDBA Dakota School of Lending Principles is a learning event with one foot grounded in the classroom and one foot in the bank. This school allows students to learn the theory and process of basic lending and then put this knowledge to work in actual nuts and bolts sessions. 17
Webinar Series Register Now Presented by: at ndba.com Webinar Series First Wednesday of each month 11:00-11:45 am CT 18
The key to our success is partners like you. As NDHFA celebrates 40 years, we thank all of you for your connnued dedicaaon to creaang affordable homeownership oppons. Partner with Bell for: Reg. O loans to bank employees, insiders or directors Holding company loans and lines of credit Bank stock and ownership loans Callie Schlieman Equipment financing Call me at 701.433.7430 Participation loans Based in Fargo, N.D., specializing in bank stock and Regulation O lending YOUR BANKING PARTNER FOR LOANS OF ANY SIZE 34599 Member FDIC 34599 AD North Dakota Bankers Association 2022_Callie Schlieman.indd 1 2/10/22 5:26 AM 19
The NDBA and NDBA Services boards of directors met on Thursday, February 17. Back Row: Pete Jahner, Kirkwood Bank & Trust Co., Bismarck; Lee Weisbeck, Starion Bank, Mandan; Bernie Sinner, BankNorth, Casselton; Jona Ziemann, Starion Bank, Mandan; Tory Hart, Bank Forward, Jamestown; Drew Olafson, United Valley Bank, Cavalier 3rd Row: Rick Clayburgh, NDBA, Bismarck; Ryan Hertz, Dacotah Bank, Minot; Cayle Paulson, Dakota Heritage Bank, Harvey; Jeff Weiler, Bank of North Dakota, Bismarck; Ann Reich, NDBA, Bismarck 2nd Row: Brian L. Johnson, Choice Bank, Grand Forks; Lori Leingang, Bank of North Dakota, Bismarck; Kathy Torske, Bravera Wealth, Bismarck; Jeremy Skoglund, Bank of North Dakota, Bismarck; Deneen Axtman, Cornerstone Bank, Fargo; Kelly Hoeven, The Union Bank of Glen Ullin; Jay Leis, Choice Bank, Fargo Front Row: Dorothy Lick, NDBA, Bismarck; Jeff Leuthold, American State Bank & Trust Company of Williston; Pat Lorenson, Ramsey National Bank, Fargo; Duane Bowman, Dakota Western Bank, Bowman; Joe Watzke, Bell Bank, Moorhead MN; Christie Huber Obenauer, Union State Bank, Hazen Bankers Enjoy Sunshine and Excellent Content at Bank Management Conference Warm weather, sunshine, and an amazing resort welcomed 140 Special thanks to the sponsors whose support and partnerships bankers, business partners, spouses and guests who attended made this event possible: the 2022 NDBA/SDBA Bank Management Conference, Platinum: held February 18-19 at The Westin Kierland Resort & Spa in Ascensus Scottsdale, AZ. The Baker Group Bell Bank The conference program featured presentations on trends BHG Bank Group changing banking, the fight against phishing, information Colliers Securities on cryptocurrency, hot mobile banking apps, 2022 market Federal Home Loan Bank of Des Moines conditions, and legal updates from speakers Chris Nichols of IntraFi Network Midwest Bankers Insurance Services SouthState Bank, Jon Burmeister of Fiserv, Jon Waldman of NDBA Services SBS Cybersecurity, Dave DeFazio from StrategyCorps, NDBA SBS CyberSecurity General Counsel Tracy Kennedy, and Jeff Caughron of The Baker Group. NDBA Chair Christie Huber Obenauer and Gold: American Bankers Association SDBA Chair Kristina Schaefer shared thoughts on leadership Arctic Wof for the future. Conference of State Bank Supervisors (CSBS) For the final general session, all gathered for an inspirational D.A. Davidson & Co. presentation by former FBI agent Cassi Chandler of Vigeo Dakota Carrier Network Graduate School of Banking at the University of Wisconsin-Madison Alliance. Cassi encouraged attendees to lead by serving and Raymond James embrace forming connections toward common goals. SHAZAM UMB Bank 20
NDBA Past Chairmen Attend Special Dinner Left to Right: Christie Huber Obenauer, Steve Rehovsky, Tom Stennes, Tim Hennessy, Lorren Henke, Todd Steinwand, Greg Schwab, Vaune Johnson, Corey Cleveland, Roger Monson, Tim Siegle, Roger Berglund, Jerry Willer, Harvey Huber, and Les Nesvig 21
FEBRUARY 2022 EDITION LIVE WELL. WORK WELL. MONTHLY HEALTH & WELLNESS NEWSLET TER REDUCING YOUR STRESS DURING Take Charge of Your Stress Managing stress is good for your health and well-being.Taking steps to AMERICAN HEART MONTH reduce your stress will improve your overall health. Try these tips: According to the Centers for Disease Control and Prevention (CDC), heart • Simplify your schedule. If you’re feeling rushed or too busy, prioritize disease is the leading cause of death in the United States. In fact, half of essential items on your calendar and to-do lists. all Americans are currently considered “at risk” for heart disease, and that figure continues to rise. Due to the prevalence of the disease, February • Practice relaxation techniques. Try listening to relaxing music to help is recognized as American Heart Month to raise awareness about heart you calm down or look into stress management or relaxation classes. disease and prevention. To celebrate, you can focus on dialing down your stress level. • Get enough sleep. Adults should strive for seven to nine hours of quality sleep each night. Stress and Heart Health While there are risk factors that contribute to heart disease that you can’t • Exercise regularly. Movement can get your blood and endorphins control, there are many things you can do to maintain your heart health. flowing, relieving stress, tension, anxiety and depression. One of those things is to reduce your stress. Having too much stress for too long is bad for your heart. • Maintain social connections. It’s important to make time for friends and family and talk with people you trust. If the stresses in your life become more than you can bear or manage with these techniques, consider seeking professional assistance. . Some people may handle their stress with poor health behaviors—such as smoking, eating unhealthy foods and drinking alcohol. Such behaviors can put you at an increased risk for heart disease and stroke. Zywave, 2022. This article is intended for informational purposes only and is not intended to be exhaustive, nor should any discussion or opinions be construed as professional advice. Readers should contact a health professional for appropriate advice. © 2021 Zywave, Inc. All rights reserved. 22
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