SDBANKER - SDBA Elects 2020-2021 Officers - OFFICIAL PUBLICATION OF THE SOUTH DAKOTA BANKERS ASSOCIATION | JULY 2020 - South Dakota Bankers ...
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SDBANKER OFFICIAL PUBLICATION OF THE SOUTH DAKOTA BANKERS ASSOCIATION | JULY 2020 SDBA Elects 2020-2021 Officers
South Dakota Bankers Association 2021 Scenes of South Dakota Calendar February The South Dakota Bankers Association is pleased to offer you the Scenes of South Dakota Calendar. This 2020 SUN MON TUES “Winter Cattle” by Dan Ray | Rapid City calendar will feature photos of South Dakota submitted by South Dakota bankers, their family members and January 2020 March 2020 WED S M T W T THUR 1 F S S M T W T FRI 5 6 7 8 2 3 4 9 10 11 1 2 3 4 5 F S 6 7 SAT 12 13 14 8 9 10 11 1 15 16 17 12 13 14 19 20 21 18 15 16 17 22 23 24 18 19 20 FIRST QUARTER 26 27 28 25 22 23 24 21 29 30 31 25 26 27 29 30 31 28 customers. Your bank logo and name can be printed on each calendar to display in homes and businesses all 2 Groundhog Day 3 4 5 6 7 8 year long. Calendar orders are due by September 1, 2020, to get the low price of $1.35* per calendar. Super Bowl 9 FULL MOON 10 11 12 13 14 15 Each order will have an additional $25.00 production charge. LAST QUARTER 16 17 Lincoln’s Birthday 18 19 Valentine’s Day 20 21 22 President’s Day 23 NEW MOON 24 25 26 The Scenes of South Dakota calendars are exclusive to SDBA member banks. These calendars are a great 27 28 29 Mardi Gras Ash Wednesday opportunity to thank your customers for their business and promote your bank. The SDBA logo is also included to emphasize the strength and security of South Dakota’s banking industry. Please see the information below and order today! All orders will be shipped November 1, 2020. Name cha | Hecla Bank by Jan Siemu “Baby Fox” SAT h2020 FRI 7 Marc 3 THUR WED 6 TUES 5 4 Email MON SUN ER 2 FIRST QUART 14 1 13 12 11 FULL MOON 10 9 21 8 20 Phone Fax Dayligh 15 t Saving Begins 16 LAST QUART ER 17 18 19 Begins 28 27 Spring St. Patrick ’s Day 26 25 Ag Week Ends 24 National NEW MOON Address 2020 April 23 2020 W T F S 22 S February M T W T F S 1 S M T 5 6 7 8 1 2 9 10 16 17 3 4 11 18 Ag Day 7 8 14 15 25 National 4 5 6 15 12 13 21 22 23 24 2 3 13 14 19 20 30 11 12 22 28 29 9 10 20 21 26 27 31 18 19 29 Begins 16 17 27 28 Ag Week 25 26 National 23 24 30 29 City State Zip Quantity (minimum order 100) CUSTOM IMPRINT April2020 “Double Rainbow” Please note: Imprint Area for bank logo and/or name is 10.375” wide x 1.25” tall. by Tom Heylens | Bruce SUN MON March 2020 TUES May 2020 WED S M T THUR 1 W T 1 2 F S S M T FRI 2 3 4 W T 8 9 10 11 5 6 7 F S FIRST QUARTER SAT 3 12 13 14 1 2 15 16 17 3 4 4 18 19 20 5 6 7 21 8 9 22 23 24 10 11 12 25 26 27 13 14 15 28 17 18 19 16 Bank logo and/or name to imprint needs to be provided in an Illustrator EPS or high resolution TIF file (300 29 30 31 20 21 22 24 25 26 23 27 28 29 31 30 5 6 April Fool’s Day 7 FULL MOON 8 9 10 Money Smart Week Begins 11 dpi) and emailed to abousa@sdba.com. Please supply all linked art and fonts required to print your file.** Palm Sunday 12 13 Passover Begins 14 LAST QUARTER 15 Maundy Thursday Good Friday 16 17 Money Smart Week Ends 18 Use same imprint from the 2020 Scenes of South Dakota Calendar. Easter 19 20 21 22 Passover Ends NEW MOON 23 24 25 Administrative 26 Professionals’ Day Teach Children Black bank logo (FREE) OR Color logo (add $100 to order) to Save Day 27 28 Earth Day First of Ramadan Begins 29 30 FIRST QUARTER Arbor Day New calendar order (Please provide bank logo/name according to file requirements above.) We’ve ordered before, but have changes to our imprint area. (Please note changes in the Special Requests area.) Would you like a proof emailed to you? Yes No, I do not need to see a proof. Special Requests: “Small Creek” by Danielle Nowell | Hitchcock **$65.00/hour (prorated) charge may apply if logo or imprint design changes need to be made to artwork supplied. May2020 MON TUES WED THUR 1 FRI 2 SAT SUN June 2020 April 2020 F S T S M T W T F S 4 5 6 S M T W 1 2 3 2 3 4 12 13 1 7 8 9 10 11 May Day 9 10 11 17 18 19 20 9 7 8 5 6 18 14 15 16 27 15 16 17 24 25 26 12 13 14 19 20 21 22 23 24 25 21 22 23 28 29 30 7 FULL MOON 8 6 29 30 26 27 28 4 5 3 Prayer National Day of Teachers’ Day 16 HOW TO SUBMIT YOUR ORDER Cinco de Mayo 14 LAST QUARTER 15 12 13 10 11 Day Armed Forces Memorial Day Peace Officers 22 NEW MOON 23 Mother’s Day 20 21 18 19 17 MAIL TO: FAX TO: PHONE: 24 25 26 27 28 29 FIRST QUARTER 30 South Dakota 605.224.7835 800.726.7322 31 Eid al-Fitr Begins Pentecost Memorial Day Bankers Association ATTN: Alisa Bousa EMAIL TO: WEBSITE: PO Box 1081 abousa@sdba.com sdba.com/calendar Pierre, SD 57501 *Pricing Information: Orders placed by September 1, 2020 receive the low price of $1.35 per calendar. After September 1, price is $1.61. Each order will have an additional $25.00 production charge (layout for press run, in-house press proof, boxing, labeling), plus shipping. Logo will be black unless color is requested. Send no money now. Orders will be billed when shipped. Orders cannot be accepted after September 15, 2020.
SDBANKER OFFICIAL PUBLICATION OF THE SOUTH DAKOTA BANKERS ASSOCIATION JULY 2020 | sdba.com PO Box 1081 | 109 West Missouri Avenue Pierre, SD 57501 605.224.1653 | 800.726.7322 www.sdba.com SDBA OFFICERS CHAIR Steve Bumann, BankWest, Inc., Pierre CHAIR-ELECT Kristina Schaefer, First Bank & Trust, Sioux Falls 8 11 VICE CHAIR David Bangasser, Dacotah Bank, Sioux Falls IMMEDIATE PAST CHAIR Shawn Rost, First Interstate Bank, Rapid City SDBA BOARD OF DIRECTORS Jesse Block, First Fidelity Bank, Platte Dylan Clarkson, Pioneer Bank & Trust, Belle Fourche Craig Davis, First National Bank, Pierre Jeff Davis, Bryant State Bank, Bryant Mike Klumpp, Citibank, Sioux Falls Pete Mehlhaff, Great Plains Bank, Aberdeen 14 18 David D. Nelson, First Fidelity Bank, Burke Brad Seaman, BankNorth, Aberdeen features SDBA STAFF Curt Everson, SDBA President 7 SDBA News ceverson@sdba.com l SDBA Announces Retirement of President Curt Everson Mike Feimer, President of Insurance and Services l SD Bankers Foundation: New Mission, New Scholarship Program mfeimer@sdba.com 8 SDBA Board Halley Lee, Administrative Vice President SDBA Membership Elects 2020-2021 Officers hlee@sdba.com Alisa Bousa, Communications Coordinator 10 SDBA Board abousa@sdba.com Two Appointed to SDBA Board of Directors Nadine Kepford, IS/Business Manager nkepford@sdba.com 11 Emerging Leaders Emerging Leader of the Month: Jason Appel Jeanine Dyce, Administrative Assistant jdyce@sdba.com 12 SDBA News Dean Franzen, Commercial Lines Specialist Bankers Take Part in Virtual Business Meeting, FDIC Town Hall dfranzen@sdba.com 14 Compliance Michelle Guthmiller, Insurance Specialist Reopening Branch Lobbies mguthmiller@sdba.com Robin Feimer, Insurance Specialist 18 Regulatory rfeimer@sdba.com COVID-19 Loan Modifications: It is More Than Just a TDR Issue EDITORIAL: Published monthly by the South Dakota Bankers Association, SDBANKER Magazine is dedicated to in every issue enhancing the state’s banking profession by providing useful and timely information on important events and trends in the 4 Message from the Chair banking industry. Statements of fact and opinion are made on The Search for a New SDBA President the responsibility of the authors alone and do not represent the opinion or endorsement of the SDBA. The magazine 5 From the Executive Office welcomes news from SDBA members. Articles may be 2020—A Year of Firsts reprinted with permission. Email abousa@sdba.com. 6 SDBIS Update ADVERTISING: Advertisements within this publication do New Product Alert: Mortgageholders Coverage Program not necessarily represent endorsement of those products and services by the SDBA. The editor reserves the right to refuse any advertisement or editorial copy deemed to be unsuitable. 16 Ask the Appraiser For advertising details, see SDBA media kit at www.sdba.com. Record Keeping Rule SUBSCRIPTIONS: Member banks, branches and associate 20 Bank Notes members receive one complimentary subscription. Additional subscriptions are $45 per year for members or $90 for non- 22 Classifieds members. Call 605.224.1653 or email abousa@sdba.com. 23 Education Calendar sdba.com | JULY 2020 | SDBANKER 3
message from the chair..... BY STEVE BUMANN | CFO | BankWest, Inc., Pierre The Search for a New SDBA President O ver the past year, I have enjoyed reading 2019-2020 SDBA Chair Shawn Rost’s monthly “Curt has been a wonderfully- messages in SDBANKER Magazine. He is a gifted effective association president writer and has done a wonderful job as chair of the SDBA, so I have big shoes to fill as the new chair. I have for nearly two decades. His to admit that the one duty that I was most concerned departure will leave a big hole about was the writing of the monthly chair’s message! I was planning to have my first message reiterate in the organization.” and expand on the vision and themes that I thought should be set out for the Association. However, that message can be written in the future. If you were one president for nearly two decades. His departure will of the 100-plus participants in the Association’s Virtual leave a big hole in the organization. I plan to extol the Annual Business Meeting that was held on June 9, you virtues of Curt as his retirement nears. (Hey, it just heard SDBA President Curt Everson announce his plan dawned on me I have a plan for 25% of the messages to retire by the end of 2020. (See the story on page 7.) that need to be written. I feel better already.) Curt has been a wonderfully-effective association Curt informed the SDBA Board of Directors in 2019 that he was planning to retire in 2020, so we actually began working on a plan for the president position in the fall of 2019. The global pandemic that we have all been dealing with this year has delayed the start of the search process. However, as things begin to loosen up, we are now ready to focus on the search for a new president. At the SDBA Board of Directors meeting on June 8, the Board charged me with the responsibility of forming a search committee to facilitate the selection of a new president of the Association. Immediate Past Chair Shawn Rost from First Interstate Bank, Chair-Elect Kristina Schaefer from First Bank & Trust, Board Member Jeff Davis from Bryant State Bank and Competitive Rates Board Member David Nelson from First Fidelity Bank Downpayment Assistance were asked and have agreed to join me on the search Closing-Cost Assistance committee. If you have thoughts or ideas, please pass them along to one of the search committee members. …FOR SOUTH DAKOTA HOMEBUYERS! In the coming days and weeks, we will be advertising the position, gathering and screening the applications, selecting candidates for interviews, interviewing candidates and ultimately recommending a candidate to the full Board of Directors. Curt has been gracious enough to offer to continue to serve to the end of the year in order to give us the time that we need to do a good job in this selection process. Steve Bumann is CFO at BankWest, Inc. in Pierre. Bumann can be reached at 605.945.3749 or Steve. Bumann@bankwest-sd.bank. 4 SDBANKER | JULY 2020 | sdba.com
from the executive office..... BY CURT EVERSON | President | South Dakota Bankers Association 2020—A Year of Firsts 2 020 continues as a year of firsts in so many loan forgiveness application forms started to erode ways. One of those firsts occurred on June 9, prospects for forgiveness, we took action. when more than 100 SDBA member bankers and On May 27, 50 state banking trade associations business partners “attended” the Association’s Annual signed a joint letter to Treasury and SBA urging them to Business Meeting virtually via Zoom. consider a de minimis threshold under which borrowers In a normal year, bankers would have gathered with outstanding loans might receive 100% PPP loan together on that day in a Bismarck Ramkota meeting forgiveness through completion of a “PPP-EZ” form—a room to honor long-serving bankers, thank Board simple one-page attestation—acknowledging that they members for their service to the industry, remember spent the majority of PPP funds to preserve the jobs bankers we lost in the past year, and to elect a new of their employees. SDBA and a host of other state slate of SDBA officers for the coming year. And so we associations initiated and submitted joint letters with did, just not face-to-face. business trade and industry associations in their states, Thanks to everyone who took an hour out of their pressing for adoption of a PPP-EZ process. South day to support the ongoing business of the SDBA. We Dakota’s letter was sent on June 2. Lastly, our own Sen. have learned that much can be accomplished through Mike Rounds decided to send his own letter, signed virtual meetings. But, we also are learning what is lost on June 12 by 44 senators, to the PPP administrative when groups of 10 or more cannot gather. agencies urging the development of a one-page During the meeting, I touched on bankers’ simplified forgiveness form for any PPP loan under commitment to community evidenced during the $250,000. coronavirus pandemic. While governments considered As a result of the efforts of many, SBA on June stay-at-home mandates, we made sure that banking 18 released a three-page “EZ” PPP loan forgiveness was recognized as an essential service. Bankers found application, requiring less documentation and fewer ways to maintain social distance while providing calculations than previously required for borrowers who customers access to the banking system. meet any one of these three criteria: When Congress decided small businesses should • Applied for the PPP loan as self-employed, an have access to fresh capital through Paycheck independent contractor or a sole proprietor with Protection Program (PPP) loans, banks and bankers no employees. stepped to the plate. By June 20, South Dakota banks had originated and funded the lion’s share of $1.65 • Did not reduce salary or wages for any employee billion in loans to 21,752 small businesses. Thousands by more than 25% and did not reduce the of bankers overcame creaky systems and ever-evolving number of hours of their employees (excepting guidance, often working around the clock to deliver laid-off employees who refused an offer to badly-needed cash to business owners trying to keep return). paychecks coming to their employees. Thanks to all for • Did not reduce salary or wages for any employee your unwavering support of your communities during by more than 25% during the covered period these uncertain times! and experienced reductions in business activity Even though $128 billion of federal spending because of health directives related to COVID- authority in support of SBA guarantees remains for PPP 19. loans, much industry and trade association attention has shifted to the forgiveness side of PPP. Members While unlikely that most groups advocating a of Congress who voted nearly unanimously in support simple loan forgiveness process are completely of the CARES Act understood that PPP-funded loans satisfied with the SBA’s latest form and instructions, were intended to be loans-in-name-only. The purpose many borrowers and lenders are in a better place than of loan forgiveness was to turn those loans into grants. when this debate began. When certain Treasury/SBA rules, FAQs and complex Continued on page 9 sdba.com | JULY 2020 | SDBANKER 5
south dakota bankers insurance & services update..... BY MIKE FEIMER | President | South Dakota Bankers Insurance & Services Inc. New Product Alert: Mortgageholders Coverage Program A few times a year we run across a good article Being proactive helps, but there’s always the from one of our vendors. OneBeacon Financial possibility of an oversight. Services, an SDBA associate member, is one of Insurance could lapse without your knowledge, and our preferred vendors that does an excellent job for an endorsement approach may no longer be the best many of our banks. solution for protection. The benefit of OneBeacon’s Mortgageholders Coverage Program is that there are By Betsy Good, CPCU, Vice President, OneBeacon more than 15 different insuring agreements available, Financial Services with ample room for flexibility for a customized solution E conomic risks and exposures that meets your needs. Here are just a few of the associated with mortgage coverage highlights: portfolios have become more • No vacancy provision complex; so has protecting banks from losses. As a response to this, • No hard and fast warranty OneBeacon Financial Services has • Admitted coverage created a new policy to account for • Mortgageholder’s liability is written on an different types of losses that could occurrence basis with defense outside impair mortgages, as well as certain exposures from originating and servicing loans. • Multiple options for balance of perils The new Mortgageholders Coverage Protection • Post termination coverage extends liability (MCP) policy is divided into three sections: coverage for up to a year after mortgage 1. Mortgageholder’s Interest satisfaction 2. Foreclosed Property Take this time to review and upgrade your protection. Visit onebeaconfs.com for more information 3. Mortgageholder’s Liability on MCP, or contact Betsy Good at egood@onebeacon. Each section contains multiple available insuring com or 781.332.8357. agreements, creating a broad and flexible product offering that allows you to select options to tailor Betsy Good, CPCU, vice president at OneBeacon coverage to your needs. Financial Services underwrites, markets and develops specialized products to insure collateral for financial Some questions to keep in mind when reviewing your institutions. Good has been a senior executive in the borrower’s insurance policies: commercial insurance industry for major carriers and 1. Is the insurance covered by an escrow brokers for more than 25 years. account you control? Make sure you have documentation that the insurance is in force. OneBeacon Financial Services, an SDBA associate Mistakes have been made when lenders assume member and preferred provider, offers property and an installment payment covered the whole year. casualty coverages for commercial banks, savings banks and savings and loan institutions, security broker- 2. If you don’t escrow money for the insurance, do dealers, investment advisors, insurance companies you have evidence of insurance in hand? When and credit unions. Specialty coverages, including does it expire? Is it still in force? management liability, professional liability, cyber liability 3. Be proactive—if a mortgage is delinquent, and financial institution bond are additionally available contact the insurance agent and make sure for institutions with less than $3 billion in assets. For coverage is in force. Give the agent your more information, visit www.onebeaconfs.com. contact information should anything come up. 6 SDBANKER | JULY 2020 | sdba.com
sdba news..... SDBA Announces Retirement of President Curt Everson T he SDBA on June 22 fresh approach.” announced the impending SDBA Chair Steve Bumann, CFO for BankWest in retirement of its president, Pierre, will lead a committee of bankers in the search Curt Everson. and selection of a new SDBA president. Following 20 years of service in “We are going to take some time finding the state government, Everson has led person with the right mix of public policy advocacy, the 136-year-old Association since communications and proven leadership skills September of 2002. The role of the required to manage an ever-changing organization SDBA, located in Pierre, is to help educate, advocate and industry,” Bumann said. and grow a diverse mix of financial institutions For information on the position of SDBA throughout the state. president and applying, visit www.sdba.com/ “I am grateful for the privilege I was given to president. Individuals interested in applying for the lead this esteemed Association and to work with position should send a letter of application with dedicated bankers and great community leaders for a resume, references and salary requirements to: nearly two decades,” Everson said. “By the end of Mr. Steve Bumann, Chair, SDBA Executive Search this year, it will be time for me to retire and hand Committee, PO Box 998, Pierre, SD 57501 or email to over the reins to someone with new ideas and a applications@sdba.com. South Dakota Bankers Foundation: New Mission, New Scholarship Program T he South Dakota technical school students with an expressed interest in Bankers Foundation banking/financial services. (SDBF) was established There is no match required by member banks, in the mid-1980s with the however, banks may choose to supplement this $2,000 broad purpose of promoting award to increase the attractiveness of the scholarship. and supporting banking and Banks must award the $2,000 as one scholarship. financial education in South Dakota. Last year, the SDBF Applications must be submitted through the parent Board of Directors updated the Foundation’s mission bank, however, scholarships may be awarded through statement to “Developing South Dakota Banking any of the organization’s locations. Information on Industry Professionals.” applying for the new $2,000 scholarships will be In support of this redefined mission, the SDBF is available this fall. For more information, visit www. redesigning its scholarship programming into a broader sdba.com/scholarships. scholarship opportunity that will more directly help to In addition to the new program, the SDBF will build and sustain South Dakota’s banking workforce. continue to award its five named scholarships—David Beginning this November, the high school scholarship S. Birkeland, Deb Gates, Alan M. Graff, Joyce Hazeltine program along with post-secondary scholarship and Herman Lerdal scholarships. funds previously given directly to seven educational In support of the Foundation’s new mission, the institutions in the state will be absorbed into a new SDBA is also providing internship development and scholarship program. career awareness resources for banks at www.sdba. SDBA member banks will now be given the com/banking-career-awareness. opportunity to apply for one of 40, $2,000 scholarships. If you have questions on the scholarships, The scholarships must be awarded to South Dakota internship development or career awareness resources, college juniors/seniors with an expressed interest in contact SDBF Executive Director Halley Lee at hlee@ banking/financial services or second year South Dakota sdba.com or 605.224.1653. sdba.com | JULY 2020 | SDBANKER 7
sdba board..... SDBA Membership Elects 2020-2021 Officers S DBA membership elected officers for 2020- years, she has also held the titles 2021 at the SDBA’s Annual Business Meeting of general and corporate counsel. on June 9. The meeting was held virtually due Prior to joining the bank, Schaefer to the cancellation of the NDBA/SDBA 2020 Annual worked as an attorney in a private Convention. The 2020-2021 SDBA officers are: practice where she specialized in • Chair: Steve Bumann, CFO, BankWest, Inc., banking law and general corporate Pierre law. Before attending law school, she was employed at First Bank • Chair-Elect: Kristina Schaefer, General Counsel & & Trust and worked in customer Chief Risk Officer, First Bank & Trust, Sioux Falls service and risk management. • Vice Chair: David Bangasser, Southern Region Schaefer regularly coaches Girls on the Run and President, Dacotah Bank, Sioux Falls is on the Helpline Board of Directors. She also serves as a mentor to two young girls as part of the LSS • Immediate Past Chair: Shawn Rost, South School Based Mentoring Program and is active in its Dakota Market President, First Interstate Bank, Everyday Heroes Recruitment Campaign and Advisory Rapid City Committee. She was also a member of South Dakota’s Elder Abuse Prevention Task Force. Schaefer was Chair Steve Bumann named the 2019 South Dakota Women in Law Attorney Steve Bumann is the CFO for of the Year. BankWest, Inc. in Pierre. He began Schaefer and her husband, Scott, have two his employment with BankWest as daughters: Olivia (13) and Harper (8). vice president of finance in 1984. He has worked in BankWest’s finance department for his entire Vice Chair David Bangasser 36-year banking career. Prior David Bangasser is southern to joining BankWest, Bumann region president for Dacotah worked for the Department of Bank in Sioux Falls. He began his Legislative Audit and a local Pierre banking career in 1982 working CPA firm. Bumann graduated from the University of for Western Bank in Sioux Falls. South Dakota in 1975 with a BS in accounting and He went on to work in St. Paul at passed the CPA exam in 1977. Heritage National Bank, Firstar Bumann is currently a member director for South Bank of Minnesota and American Dakota on the Federal Home Loan Bank of Des Moines National Bank. He joined Dacotah Board. He is also on the Elder Board of his local church. Bank in 1995. His past service includes seven years on the Pierre Bangasser is board chair and a classroom volunteer School Board, a term on the South Dakota Retirement for Junior Achievement of Sioux Falls and a board System Board of Trustees as the school board member for Singing Boys of Sioux Falls, as well as past representative and he is a past president of the Pierre service with El Riad Shriners, Sioux Falls Chamber of Area Chamber of Commerce. Commerce and Zoological Society of Sioux Falls. Bumann and his wife, Deb, who will be married Bangasser and his wife, Karen, have been married for 37 years in July, have four adult children and five for 38 years. They have one daughter, Megan Hartz. grandchildren. Aaron and his wife, Erin, are in Kansas Megan and her husband, Dusty, have two children: City; Michael and his wife, Kimmie, are in Chicago; Brian Cohen (13) and Cade (12). is in Minneapolis; and Elizabeth and her husband, Chris, are in Rapid City. Immediate Past Chair Shawn Rost Shawn Rost is the South Dakota market president Chair-Elect Kristina Schaefer for First Interstate Bank. Rost and his wife, Susan, Kristina Schaefer serves as general counsel and live in Rapid City. Shortly after graduation from Black chief risk officer for First Bank & Trust. Schaefer serves Hills State University, he was hired as a consumer as the organization’s primary legal resource and also loan officer in Spearfish. From there, Rost was named oversees the compliance, fraud, BSA/AML, audit, ERM and third-party oversight functions. During the past 13 Continued on next page 8 SDBANKER | JULY 2020 | sdba.com
the Deadwood branch president and then the Sturgis branch and A Year of Firsts...continued from page 5 Northern Hills market president. By now, many of you have heard that I am planning He was promoted to his current to retire. It has been my great privilege to lead this position in 2016 and has worked esteemed Association for the past 18 years. I feel for First Interstate Bank for 28 lucky to have worked with so many great bankers and years. community leaders. But, the time has come for me to Rost has been on the SDBA step aside and for someone with a fresh perspective Board of Directors for the past to take the reins. I am humbled by the congratulatory six years. He is passionate about notes I have already received from bankers and peers SDBA advocacy efforts, finding ways for banks to across the country. This may sound kind of weird, but I become more profitable so they can better invest in feel like I am about to finish a very interesting book and the communities they serve, and encouraging more am starting to wonder what I should read next. bank employees to become active in the SDBA. Rost But as the unfortunate man from the plague- currently serves on the South Dakota Community stricken village in “Monty Python and the Holy Grail” Foundation Board of Directors and in the past said, “I’m Not Dead Yet!” There are projects to served on the executive boards of many nonprofit complete and files to thin. I plan to be a resource during organizations including the Northern Hills Training this period of transition, but I will not be a roadblock. I Center in Spearfish, the Deadwood Chamber of wish the volunteer leaders of the SDBA much success Commerce, Neighbor Works Dakota Home Resources as you begin the search for a new SDBA president. and Deadwood Economic Development. Rost and his wife enjoy traveling and spending Curt Everson is president of the South Dakota Bankers time with their three sons: Hunter (25), Tanner (23) and Association in Pierre. Everson can be reached at Traven (11). 605.224.1653 or ceverson@sdba.com. Loan Participations Structured for the Community Bank Market Rev up your loan portfolio with Dougherty Funding. As a commercial finance company we service rather than Want to rev up your compete with community banks. Our loan participations are structured for the community bank market and our current loan portfolio? portfolio has been participated to hundreds of community banks nationwide. Active relationships $5+ billion with over in loans 500 originated community banks since 1996. nationwide. Over Loan servicing 500 portfolio financings averaging since 1996. $1.5 billion Corporate Headquarters: Minneapolis, MN • Ph: 612.317.2000 | 800.227.0786 www.doughertymarkets.com • Refer to website for listing of all locations. sdba.com | JULY 2020 | SDBANKER 9
sdba board.... Two Appointed to SDBA Board of Directors Mike Klumpp, Citibank, Sioux Falls Jesse Block, First Fidelity Bank, Platte Mike Klumpp was appointed to the SDBA Board of Jesse Block was appointed to the SDBA Board of Directors to represent banks in the Maximum Dues- Directors to represent the SDBA Emerging Leaders Paying Bank Category. Klumpp fills a seat previously Work Group. This is a new seat on the SDBA Board of held by Craig Hansen, which has a term of two years Directors created this year. The term for the Emerging remaining. Leaders Work Group seat is for one year. Banking Career Banking Career As site president for Citibank Jesse Block serves as a vice in Sioux Falls, Mike Klumpp president at First Fidelity Bank is responsible for driving and and manager of its Platte branch. executing site governance, He is also a member of the bank’s people strategy, site culture and Board of Directors. Block has a community involvement. A native degree in business administration of northwest Iowa, Klumpp earned from Dakota Wesleyan University. a finance degree at Iowa State He serves on the SDBA Emerging University prior to joining Citi in Leaders Work Group, which he 1988 as a financial analyst. He has chaired. Block began his has served in a variety of managerial roles in security banking career at Great Western Bank as an ag lending operations and fraud prevention and, in addition to his trainee and joined First Fidelity Bank in 2012 as an ag role as site president, is currently the director of control loan officer. In 2019, he was named VP and manager for Citi’s Global Consumer Bank Fraud Prevention and appointed to the bank’s Board of Directors. group. Community Involvement Community Involvement Block has been very involved in his community. He Throughout his career, Klumpp has had a long currently serves on the Platte Community Memorial history of sharing his time and talents. He has served Hospital Board of Directors and is the past president in leadership roles for the United Way, the Brandon and board member of the Platte Area Chamber of Valley School Board and the Brandon Valley Athletic Commerce. He has served as a board member of the Booster Club. He has represented Citi on the Visa Risk Platte Black Panther Booster Club and as a deacon at Executive Council and is a current member of the Board First Reformed Church of Platte. of Directors for Citi Trust South Dakota. Family Family Block and his wife, Amanda, have been married for Klumpp and his wife, Jean, have four adult children 12 years. They have three children: Berkley (11), Cade and reside in rural Sioux Falls. (9) and Baylor (5). Goals as an SDBA Director Goals as an SDBA Director As an SDBA director, Klumpp wants to continue Block’s goal as an SDBA Board member is to Citi’s tradition of active engagement and contribution continue to grow emerging leaders programing and to the SDBA. strengthen ties with emerging industry leaders to the SDBA and the banking industry as a whole. 10 SDBANKER | JULY 2020 | sdba.com
emerging leaders..... Emerging Leader of the Month: Jason Appel A s part of the SDBA’s mission to grow South is an important part of my job and a part of my job Dakota’s future bank leaders, we are featuring a I’ve always cherished. Over the last few years, I’ve monthly emerging leader. This month’s feature devoted more time to developing our banking team and is on Jason Appel, Plains Commerce Bank, Sioux Falls. investing a significant amount of time to be a spark to their personal and professional growth. My co-workers, First-Ever Job our customers and the people in our trade area bring My first work experience me back to work each day. I enjoy taking care of was as a plumber, working people and thrive in a fast-paced, make-it-happen-now for my dad. I did that during environment. summers for nearly 10 years, and I really enjoyed the chance What Motivates Him to work with him. He taught My parents—mother, father and stepfather— me to value hard work and sacrificed basically all of their time and resources to physical labor. He also taught invest in me during my youth. While we never really me that time matters—work had a lot, they always found a way to take care of my and problem solving need to needs. My education was my mom’s top priority, and be done in an efficient manner she is so proud that I went to college and got a degree. so that everyone working What motives me is keeping that momentum going for around you can do their jobs. my children and making sure they have opportunities While I today enjoy a desk job, some days I do miss to do more than I did to ensure they can have a greater being able to walk off a job site and physically see the impact on this world than I can have. I want to pay that progress you made that day. forward for my parents and grandparents. Emerging Leader Story If He Could Have Any Job I have worked in banking for 17 years, in business I grew up wanting to be a farmer and still love big banking for 15 years, and have been with Plains equipment and the thrill of harvest. I also think that Commerce Bank for almost 10 years. I have never really working in the shipyards at our largest ports on the asked to be a leader, but I get asked to lead quite often, east coast would be an amazing experience. There is which is very rewarding. It is nice to know others see something about shipping and how those immense it in me, even at times when I don’t see leadership in amounts of goods get from where they are to their end myself. Leadership and leadership development appear destinations that interests me. to be a lifelong journey, and I’m working hard to scale the leadership levels and get those around me to buy in and improve as leaders as well. I’m finally getting out In His Spare in front of leading, seeing challenges and opportunities Time before others see them, and trying to be prepared for I enjoy being situations and opportunities. I was completely reactive outside. I grew up for a long time—waiting for a situation, making a plan hunting and fishing, and then acting. I think that learning and improving is but life has limited what leadership is all about. that for me, so I took up golf. While I am What He Most Likes About His Job not very good at golf, As a branch manager at Plains Commerce Bank, it has become my I oversee the commercial and ag lending facets of connection to nature. our business in the Sioux Falls market. I interact with I enjoy walking the our consumer banking group as well, but over the course and seeing that last few years new leaders have stepped up to run part of nature. I enjoy those departments, which has allowed me to focus on the rare visit to a lake, business banking. I oversee a loan portfolio and am in and I certainly enjoy charge of growing my portfolio and helping the team time with my close Jason and Jamie Appel and around me grow theirs as well. Maintaining our existing friends, my family and their children: Briggs (9), Jorja banking relationships and developing new relationships our team at the bank. (5) and Beckett (2). sdba.com | JULY 2020 | SDBANKER 11
sdba news..... Bankers Take Part in SDBA Virtual Business Meeting, FDIC Town Hall M ore than 100 bankers and FDIC Virtual Town Hall business partners took part South Dakota and North Dakota in the SDBA’s Virtual Annual bankers and business partners Business Meeting via Zoom on June joined for a Virtual Town Hall with 9. The meeting is traditionally held FDIC Chair Jelena McWilliams during the SDBA/NDBA Annual following the SDBA’s Annual Convention, which was canceled Business Meeting on June 9. this year due to the pandemic. Originally scheduled to speak at the The Annual Business Meeting’s Annual Convention, McWilliams and agenda included the election of her top deputies provided a timely SDBA officers (see the story on update and answered questions page 8), comments from the posted by the event moderator, outgoing and incoming SDBA ABA President Rob Nichols. Issues chairs, an association update from ranged from COVID-19 to the SDBA President Curt Everson and a 2019-2020 SDBA Chair Shawn Rost future of community banks, which South Dakota Bankers Foundation McWillaims called the lifeblood of update from Halley Lee. communities. “The greatest accomplishment • Mary Jo Kuhlman, “I am very proud of the I think the South Dakota Bankers Commercial State Bank, work that you are doing in your Association had this past year Wagner communities. I know that your was advocating for our industry • Patricia M. Lien, Dacotah communities are largely rural. In with our congressional delegation Bank, Watertown a lot of those communities, you and working to show them the • Daniel N. Menking, Dacotah are it. You are just not the banking problems with the PPP program Bank, Webster presence, you are the epicenter and helping them modify the • Nancy K. Rausch, Plains of the economy’s activity,” rules and change the process Commerce Bank, Hoven McWilliams said. “I think you have and procedures to make it easier • Randy Sachtjen, First Fidelity done a phenomenal job working for us to help our customers and Bank, Burke with your communities, and you our communities to survive this • Bonnie M. Schumacher, have a lot of exposure to different pandemic,” said 2019-2020 SDBA First State Bank of Roscoe, industries that have been heavily Chair Shawn Rost “That is what we Roscoe affected by the pandemic, including are all about.” • Denise D. Trogstad, Dacotah oil and gas, cattle ranching, Bank, Lemmon farming, etc., and you have Years of Service Awards adjusted pretty quickly.” The following bankers were In Remembrance Following the hour discussion, recognized for their years of service The following bankers who the more than 300 participants to the banking industry: passed away this past year were were treated to a bonus session • Jane F. Aman, Dacotah Bank, remembered: when James Ballentine, ABA’s Aberdeen • Jerry Feldhaus, The First EVP of congressional relations • Susan M. Aman, Dacotah National Bank in Sioux Falls and political affairs, provided an Bank, Mobridge and its previous subsidiary in inside look at what’s happening in • Mary J. Bloom, Dacotah Flandreau Washington, D.C. Bank, Webster • Gerry Berger Law, Deuel The SDBA thanks its bankers • Shelley J. Deutsch, Dacotah County National Bank, Clear and business partners who took Bank, Webster Lake part in the two virtual events. The • Lee Jacobson, Bryant State • John W. Thomson, First SDBA Board of Directors also held a Bank, Bryant Midwest Bank (ONE virtual board meeting the day prior • Shirley Kleinhans, Premier AMERICAN BANK), to the Annual Business Meeting. Bank, Alcester Centerville 12 SDBANKER | JULY 2020 | sdba.com
SDBA President Curt Everson with the SDBA’s 2020- 2021 officers: Chair Steve Bumann, Chair- Elect Kristina Schaefer and Past Chair Shawn Rost. Call me at (Not pictured is 605.321.9197 Vice Chair David Bangasser.) Todd ABA President Holzwarth Based in Sioux Falls, S.D., serving South Dakota, North We’re Here Rob Nichols Dakota Northwest Iowa, southwest Minnesota moderated a live for You virtual town hall with FDIC Chair Jelena McWilliams and South Dakota and North Dakota Things might look a little different now. We might not be able to shake your hand bankers and or meet you face to face. And just like business partners you, we’re relying more on technology on June 9. to stay connected. we’re here for you. But no matter what, And when this is all over, we’ll still be here, stronger than ever, a partner you can count on – now and SDBA President going forward. Curt Everson WHY YOU CAN BE (right) presents CONFIDENT WITH BELL a gavel to 2019- BANK AS YOUR PARTNER 2020 SDBA Chair We are and have always been downside Shawn Rost (left), risk managers. That’s part of what First Interstate makes us so strong and allows us to be Bank, Rapid City. committed to correspondent lending – a growing part of our company. As your community banking partners, we want to help you through this unprecedented time. While we’re being more conservative in our overall lending, we’re still purchasing high- quality participations and offering bank stock financing. Additionally, we can offer: A full line of insurance products The SDBA Board Business leasing opportunities of Directors held SBA loan assistance a virtual board (our SBA expert program group would be happy to answer questions meeting on June regarding SBA programs – including the 8, with some Paycheck Protection Program) board members attending the 26695 meeting in person at the SDBA office in Pierre. Member FDIC Bell Insurance Services, LLC is a wholly owned subsidiary of Bell Bank. Products and services offered through Bell Insurance are: Not FDIC Insured | No Bank Guarantee | May Lose Value | Not A Deposit | Not Insured by Any Federal Government Agency. sdba.com | JULY 2020 | SDBANKER 13 26695 AD South Dakota Bankers Association 2020 Update_Todd_V1.indd 5/14/20 2:19 PM 1
compliance..... Reopening Branch Lobbies By Kevin Kim, Associate General Counsel, Compliance Alliance M any states have begun taking their first steps toward reopening, at least partially, since the COVID- 19 pandemic, and many of our members have been trying to figure out the steps for reopening their branch lobbies. There are many considerations when reopening branch lobbies including practicing social distancing and other measures to prevent the spread of COVID-19, while keeping compliant with all the other rules and regulations that traditionally govern bank operations. crucial to not overlook the smaller first key aspect to think about is to One of the biggest concerns steps. This means that if there are encourage social distancing within is that banks want to provide a hand sanitizer dispensers in the the branch lobbies. To assist in safe work environment by having branches, someone should monitor practicing social distancing, banks customers and employees wear the dispensers, and it would be could place markers on the floor face masks, but there are also other ideal to have steps in place for to help guide customers in how risks involved by having everyone refilling them as well. far they should stand from others. in the branch wear a mask. This is To streamline this process, Additionally, banks could consider becoming a growing issue with the it could be helpful to temporarily putting signs in the branches, increasing bank robbery attempts have only one entrance/exit including at the teller and ATM since some branches reopened. available and to have the bank locations that customers should Just as how many grocery security guards at these points stand apart from one another. stores and other essential to control access to the banks’ Banks should also consider businesses have been lobbies. This would ensure that the implementing procedures to help implementing different practices banks are able to maintain their employees social distance from one for trying to keep the facilities safe maximum capacity that they have another as well. Banks could space for the public, we recommend set and that the customers will be out the tellers and bankers and banks implement procedures able to practice social distancing also possibly use separators where for cleaning and disinfecting the measures when they are inside. it is necessary (i.e. between teller branches. The banks should have a Additionally, while controlling the stations and between the bankers’ policy in place to disinfect the lobby entry point, banks could also have desks and customers). during the hours of operations, an employee accompany the guard Secondly, banks should ensure meaning the procedures would to give prescreening questions that the security cameras in the include a systematic process in and possibly take temperatures branches are operating properly. place. of the visitors to mitigate risk This includes network scans and Additionally, providing hand for everyone else inside. We making sure that all the necessary sanitizer at the entrances would have a customer prescreening patches are up to date. Banks help bank customers feel that questionnaire for the banks to use should also double check storage much safer. These procedures are in our pandemic toolkit at https:// capacity as well so that the generally not ones we had prior compliancealliance.com/uploads/ cameras can operate as intended. to the pandemic and could take files/general/COVID-19_Customer_ Recently, there have been many some time to get used. However, Prescreening_Questionnaire_ instances where situations escalate if banks are distributing hand v2.docx. and sometimes even become sanitizer in the branches, it is When inside the branches, the violent in nature when customers 14 SDBANKER | JULY 2020 | sdba.com
have been asked to wear facial With the COVID-19 pandemic covering prior to entering. In these disrupting the way we used to times of panic and paranoia, having conduct business, many states are fully-functional security cameras allowing businesses to slowly open would be crucial. And in relation back up to get back to “normal.” to these aggressive scenarios, In this attempt to get back to how having a procedure and training things used to be, banks should in place to de-escalate situations take the proper precautions to help would certainly help trying to keep both employees and customers feel everyone as safe as possible. safe, while also complying with the Another big question is regulations that continue to govern whether bank employees could bank activities. ask customers to remove their We have created a checklist facial masks and coverings for at www.compliancealliance. customer identification purposes. com/uploads/files/general/ This is essential for “know your Checklist_Covid19_Reopening-v3. customer” procedures and fraud doc and a cheat sheet at www. mitigation. Banks are allowed to compliancealliance.com/uploads/ ask customers to remove their files/general/COVID-19_Reopening_ masks to ensure that the customer Cheat_Sheet.pdf to help guide in is the correct person and matches the preparation of this task. the government identification. For more information, you There has not yet been any can watch our recent webinar for guidance from the regulators reopening branch lobbies at http:// discussing the duration of how compliancealliance.com/news- long to ask customers to remove events/a-guide-for-reopening- their face masks, but as long financial-institutions-in-covid-19. as it is reasonable, there isn’t a Additionally, a FAQ is also available prohibition in making this request on the webinar page. to the customers. Consequently, banks would be able to continue Kevin Kim joined complying with its customer Compliance identification procedures and other Alliance after Bank Secrecy Act requirements in graduating from verifying government identification the Benjamin N. documents. When following this Cardozo School of protocol, banks should remember Law in 2019. As a to ensure the camera angles are hotline adviser, he adjusted so that it can capture the currently spends his days guiding faces when the customers remove Compliance Alliance members their face masks. and writing articles for weekly and Aside from the policies and monthly publications. Before C/A, procedures during the hours of he worked at Galaxy Digital and operation, banks should think Refinitiv (formerly Thomson Reuters about their opening and closing Financial and Risk) as a law clerk. procedures. This includes both Kim also opened a cryptocurrency safety measures and cleaning the mining farm and founded an branch. If the bank is using outside after-school program business cleaners prior to and/or after in his native New York City. His business hours, banks should also unique experience and outlook vet these service providers and have brought an invaluable new make sure that they are insured dimension to Compliance Alliance. as well. Additionally, banks should For information on Compliance decide whether they would be Alliance, an SDBA endorsed vendor staggering employees’ hours as and associate member, visit www. this could help in practicing social compliancealliance.com or call distancing for the employees and 888.353.3933. staff members of the bank. sdba.com | JULY 2020 | SDBANKER 15
ask the appraiser..... BY SHERRY BREN | Executive Director | South Dakota Appraiser Certification Program Record Keeping Rule Work Files Affected by a Natural is advised to contact the applicable state appraiser regulatory agency to see if they have any guidance on Disaster what steps to take to document the loss. Question: My appraisal work files were recently Storing work files and electronic copies off site and damaged due to a natural disaster. I am salvaging what implementing a system of regular backups may serve I can but will likely have to discard many. What does to minimize future risk. USPAP require in this situation? Response: USPAP requires that work files be retained “for a period of at least five years after Appraising After a Natural Disaster preparation or at least two years after final disposition Question: A client has asked me to complete of any judicial proceeding in which the appraiser an appraisal of a property that was damaged in a provided testimony related to the assignment, recent natural disaster, but I have no experience with whichever period expires last.” If the work files are older appraisals of this type. What are my USPAP obligations than the prescribed period, then there is no USPAP in this situation? violation in discarding them. Response: USPAP requires appraisers to perform However, if the natural disaster has destroyed work competently when completing assignments. However, files that must be retained, a real property appraiser USPAP allows appraisers to acquire the necessary competency during the assignment. The COMPETENCY RULE states, in part: If an appraiser determines he or she is not competent prior to accepting an assignment, the appraiser must: 1. Disclose the lack of knowledge and/or experience to the client before agreeing to perform the assignment; 2. Take all steps necessary or appropriate to complete the assignment competently; and 3. Describe, in the report, the lack of knowledge Brian J. Gatzke, ARA, MBA and/or experience and the steps taken to Certified General Appraiser, SD & MN complete the assignment competently. 311 Third St | PO Box 63 | Brookings, SD 57006-0063 In addition, being competent includes the P: 605.692.9445 | F: 605.610.0948 info@northernplainsappraisal.com | www.northernplainsappraisal.com requirement to recognize and comply with laws and regulations applicable to the appraiser and the Our team of valuation professionals provide reports in Uniform assignment. In the aftermath of a natural disaster some Standards of Professional Appraisal Practice (USPAP), Yellow clients, particularly lenders, may include additional Book (USFLA) and IRS appraisal standards. Having grown up in assignment conditions for developing and reporting rural communities and family farms in the Dakotas, we know the value of professionalism and integrity. We specialize in: an appraisal and may waive others. In order to perform competently, appraisers involved in such assignments l Agricultural Properties l Single and Multi Family l Dairies, Farms & C.A.F.O.s l IRS must remain current on these topics. l Conservation Easements l Yellow Book (USFLA) l Wildlife Habitat l Mini-Storage Warehouses If you have an appraisal related question that you l Rural Residential l Lake Properties would like to have answered in the “Ask the Appraiser” l Commercial Properties l Estates, Donations, & Trusts column, submit it to Sherry Bren, executive director Our team also offers: consulting services, MLS research, of the Appraiser Certification Program, 308 S. Pierre agricultural land advising and real property valuation. St., Pierre, SD 57501, fax 605.773.5405 or by email to Contact us today for a personalized quote! Sherry.Bren@state.sd.us. 16 SDBANKER | JULY 2020 | sdba.com
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regulatory..... COVID-19 Loan Modifications: It is More Than Just a TDR Issue By Scott Polakoff, CAMS, Executive Vice President, FinPro M any banks across the country are at risk of CAMELS downgrades, increased deposit insurance assessment premiums and regulatory enforcement actions due to inadequate risk management practices for their COVID-19 loan modification program. Loan modifications have been part of most banks’ lending operations for many years. Before the coronavirus, such modifications were often prompted by a borrower’s “financial distress.” Banks would attempt to work with the financially- distressed borrower by granting a “concession” that the bank otherwise would not consider for other borrowers with a similar risk profile. An example of such a loan modification might be an interest rate reduction • Was the borrower impacted by COVID-19? from 5% to 3% for 12 months to help a financially- distressed borrower. Generally speaking, this type of • Was the modification pursuant to Section 4013? loan modification would be categorized as a troubled * If yes, was the loan current as of Dec. 31, 2019? debt restructure (TDR) under accounting literature (ASC * If yes, was the loan modification between 310-40) and captured as such in call reports. TDRs are March 1, 2020, and Dec. 31, 2020? considered impaired loans. • Was the modification pursuant to the Interagency Guidance? Many banks have COVID-19 loan modifications * If yes, was the loan current at time of approximating 25% of their commercial portfolio. modification? When the country became engulfed with the * If yes, was the loan modification short term coronavirus, both Congress (Section 4013 of the (i.e. six months)? CARES Act) and the regulators (April 2020 Interagency Guidance) issued material to guide banks on TDR Remember that banks must maintain records on designation for COVID-19-related loan modifications. It the number and dollar amount of loan modifications is critical for bankers to understand that while Section approved under Section 4013 and under the 4013 and the April 2020 Interagency Guidance both Interagency Guidance and report this data to the Board discuss the applicability of TDRs, they have materially of Directors on a regular basis. different requirements (modification duration, date of record for current/delinquency status, etc.) for The TDR determination is only the first step in the determining when the TDR designation is necessary. COVID-19 loan modification process. FinPro urges all banks to specifically designate whether Unfortunately, too many banks neglect to the COVID-19 loan modification was approved under implement the second step in the COVID-19 loan Section 4013 of the CARES Act or under the April 2020 modification process, which is vital to accurately Interagency Guidance. This document should be in each identify, measure, monitor and control the bank’s risk loan modification file and address the following items: profile. 18 SDBANKER | JULY 2020 | sdba.com
Banks must properly “risk rate” COVID-19 loan modifications and incorporate such risk ratings into their ALLL/ACL calculations. Loans modified under New SDBA Board Member Section 4013 or the Interagency Guidance pertain Trident Trust Company (South Dakota) Inc ONLY to borrowers who have been impacted by the Contact: Vanessa Humpal, Financial Controller coronavirus. By definition, these borrowers have Address: 200 N Phillips Ave, Sioux Falls, SD 57104 financial performance less robust than before COVID- Phone: 605.679.4353 19. In some cases, these borrowers may have serious Email: vhumpal@tridenttrust.com cash flow problems driven by the coronavirus that Web: www.tridenttrust.com impact their ability to service their debt. It is incumbent Trident Trust is a leading independent provider on banks to accurately “risk rate” these borrowers of corporate, trust and fund services to the at the time of loan modification and on a regular financial services sector worldwide. Established basis going forward. FinPro has observed that many more than 35 years ago, our clients include the banks have internally “risk rated” their COVID-19 loan world’s largest banks and brokerage firms, leading modifications to a “watch” category. law and accounting firms, and high net-worth Moreover, these new risk ratings must be individuals and their families. With 38 offices in incorporated into the ALLL/ACL calculation. One “best 23 jurisdictions, we are today among the largest practice” observed for community banks across the organizations in our industry, offering clients country is to establish a “homogenous pool sub-tier” access to a range of services that extends from within the ALLL/ACL methodology to break out all traditional corporate domicile representation such loan modifications within each homogenous pool. to the administration of complex trust and fund Noteworthy, this approach is often used in conjunction structures. Our global footprint ensures that we with a new “COVID-19 Q-Factor” that many banks service our client base across the world’s time now incorporate their ALLL/ACL methodology. Some zones. With a record of the longest average tenure banks have actually appended a one- or two-digit in our industry, our professional personnel are well code to COVID-19 loan modifications to ensure easy equipped to support our clients with their practical identification over time. knowledge and extensive experience. Lastly, effective corporate governance is critical to avoid CAMELS downgrades and enforcement actions. Corporate governance starts with a comprehensive documentation process. As noted earlier, banks must maintain records of all COVID-19 loan modifications, specifically noting whether such modifications were executed under Section 4013 of the CARES Act or the Interagency Guidance. Remember, modifications cannot fall under both categories since they have different (and competing) requirements. This information should be reported to the Board of Directors on a regular basis. Similarly, the management must inform the Board of risk rating trends for COVID- 19 loan modifications and how such ratings have impacted the bank’s ALLL/ACL. These actions, together with updated policies and procedures to incorporate coronavirus actions, robust MIS and risk management practices and comprehensive internal controls will properly prepare banks to address Contact Lee Anderbery any regulatory concerns. VP–Correspondent Services landerbery@bbwest.com Scott Polakoff, CAMS, is executive vice president with FinPro, a full- WE CHAMPION COMMUNITY BANKING service management consulting firm specializing in providing advisory services to the financial institutions industry. Polakoff joined FinPro to co-lead its regulatory practice after serving more than 22 years with the FDIC (eight years as the Chicago regional director) and four years with Office of Thrift Supervision as its chief operating officer. He can be reached at spolakoff@ finpro.us or www.finpro.us. BBWEST.COM sdba.com | JULY 2020 | SDBANKER 19
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