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INDEPENDENT BANKER
THE TEXASI N D E P E N D E N T B A N K E R S A S S O C I A T I O N O F T E X A S
NOVEMBER/DECEMBER 2017VOLUME XLIII, NO. 6
®
Who Is That Masked Man?
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PHASEONE
November/December 2017 www.ibat.org 3
INDEPENDENT BANKER
THE TEXAS
®
®
NOVEMBER/DECEMBER 2017VOLUME XLIII, NO. 6
COLUMNS 4 Up Front
CHRISTOPHER L. WILLISTON, CAE
6 General Counsel’s Corner KAREN M. NEELEY
9 Services Spotlight RONNIE A. MILLER
10 The Compliance Guy KELLY GOULART, CRCM CAMS CIA
DEPARTMENTS12 News
25 People
28 Calendars
29 New Members
29 Index of Advertisers
30 Communities
NAYLOR ASSOCIATION SOLUTIONS 5950 NW 1st Place, Gainesville, FL 32607, 800-369-6220, www.naylor.com Project Support Specialist Alyssa Woods, Publisher Heidi Boe, Sales Manager Douglas Swindler, Publication Director Doug Smith, Marketing Account Specialist Sabine Borneman, Editor Jennifer Lipner, Designer Deb Churchill Basso, Advertising Sales Reps Amy Gray, Tracy Jones, Douglas Smith
© 2017 Naylor, LLC. All rights reserved. The contents of this publication may not be reproduced by any means, in whole or in part, without the prior written consent of the publisher. PUBLISHED OCTOBER 2017/IBT-S0617/8856
INDEPENDENT BANKERS ASSOCIATION OF TEXAS 1700 Rio Grande Street, Suite 100, Austin, TX 78701, 512-474-6889, www.ibat.org
Christopher L. Williston, CAE, President and CEO, [email protected]; Christopher L. Williston VI, CAE, Executive Vice President, [email protected]; Bonnie Kankel, Editor, Vice President – Administration & Corporate Communications, [email protected].
FEATURES 14 The Man Behind the Mask
Joe Kim King, Brady National Bank
17 Best Practices: Diagnosing Your Executive Benefit Needs ROB BARTON
20 Amazon Ate My Bank: One Man’s Vision for the Apocalyptic Future of Fintech CHRISTOPHER L. WILLISTON, VI, CAE
23 Look Before You Leap: Using Simulations in a Decision-Making Framework LESTER MURRAY
page 23
page 14
4 The Texas IndependenT Banker November/December 2017
U P F R O N T
HeroesCHRISTOPHER L. WILLISTON, CAE IBAT PRESIDENT AND CHIEF EXECUTIVE OFFICER
IT WAS A beautiful fall Sunday. As was typical then, I
had just finished a round of golf and headed toward
the house. In the faint distance I could hear the
sound of fire engine sirens racing toward their
destination. I had no idea they were heading to
my house.
That was, of course, until I rounded the cor-
ner and headed down the cul-de-sac and saw the
smoke billowing from our kitchen window. My son
was outside screaming and waving his arms franti-
cally for his mother to come home from visiting a
neighbor up the street.
Thank the good Lord for Brent. He had already
rushed inside from across the street with a fire
extinguisher, working mightily to contain the flames
on the box of books that was placed on the burners
and accidentally ignited. Once the firemen arrived,
all that was left was the cleanup of the white pow-
der residue left by the extinguisher, and worse
yet, the smoke smell that seemed to permeate the
entire house.
Neighbor after neighbor soon appeared at
our door to offer a helping hand. Several brought
fans. Others brought brooms and mops. Still oth-
ers offered to shelter us until we could tolerate
the lingering odor left behind. Heroes, all of them.
That episode, as traumatic as it was, pales in
comparison to what I know my many friends down
on the Gulf Coast and the 31 counties must be deal-
ing with in the wake of Hurricane Harvey. Stories
have poured into the IBAT offices of bank branches
destroyed, people and pets being displaced and,
of course, loss of personal belongings.
How gratifying it has been to watch the stories
of great heroism. Volunteers from across the State
and throughout the Nation who raced toward the
affected areas with monster trucks and flat bottom
boats to search for anyone needing to be rescued.
Or truck after truck, and flatbed trailers, rushing
bottled water and other supplies to evacuation
centers throughout Texas.
Now the cleanup begins. This cleanup will be
measured in years, not days.
Thoughts immediately turned to how to help
and how to make a difference with so many in need.
It was foolish to think beyond what little we can do
for our friends and colleagues in the community
banking industry. In collaboration with the Texas
Bankers Association, we decided to begin a fund-
raising campaign to help storm-ravaged banker
families.
At this writing, almost $1 million has been
received into the Texas Bankers Foundation where
100 percent of the proceeds ultimately collected
will be distributed as determined by the TBA and
IBAT Executive Committees. We have yet to learn
just how many of our banker friends have been
affected, but it is gratifying to see the industry
unite and step up in such a big way to help our own.
Nothing we can do can totally alleviate the pain
and suffering inflicted on so many. But it is great
to know that we can play a very small part in help-
ing our fellow bankers rebuild their lives, just as
we have done when other disasters have affected
those in our industry.
Besides the money, our colleagues will need our
continued prayers. We pray that their recovery is
swift so that they may begin again.
Tomorrow it could be you or me who will need
the help of others. It might be as simple as clean-
ing up fire extinguisher residue or eliminating the
smell left behind, or as traumatic as experiencing
a total loss. But it is great to know that there are
always friends to offer a helping hand.
Today, it is our turn to be heroes. ■
Contact IBAT’s president and CEO—also known as
“The Boss”—at 512-474-6889 or [email protected].
At this writing, almost $1 million has been received into the Texas Bankers Foundation where 100 percent of the proceeds ultimately collected will be distributed as determined by the TBA and IBAT Executive Committees. We have yet to learn just how many of our banker friends have been affected, but it is gratifying to see the industry unite and step up in such a big way to help our own.
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Leaders in innovation. The Baker Group remains the industry leader when it comes to innovation. We are truly a one-stop shop that never outsources services. To find out how The Baker Group can assist your institution in defining and meeting its financial objectives, call your Baker representative or Ryan Hayhurst at 800.937.2257.
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6 The Texas IndependenT Banker November/December 2017
G E N E R A L C O U N S E L’ S C O R N E R
Year-End Checklist – 2017KAREN M. NEELEY IBAT GENERAL COUNSEL
• Annual report. This is prepared from
year-end call report data and should be
available to your shareholders as well as
the general public no later than March 31,
or 5 days after it is provided to sharehold-
ers, whichever is earlier.
• Proxy statement and notice of annual
shareholders meeting. Many banks have
their annual shareholders meeting in
January. If so, you need to prepare your
proxy statement, proxies, and notice
of shareholders meeting for mailing in
December.
• Identifying executive officers. Under
Regulation O certain officers are automati-
cally considered executive officers unless
the officer is excluded by a resolution of
the board of directors from participation
in major policy making functions. Do this
at the last meeting of the year or no later
than the first meeting of the next year.
• Identifying insiders. At the first board
meeting of a new board (often in January),
be sure to require directors and executive
officers to identify their related interests
as defined in Regulation O. Also, deter-
mine whether there are any “affiliates”
due to common control which would be
subject to Regulation W.
• Renew registration of residential
mortgage loan originators. The annual
renewal period means November 1
through December 31 of each year.
YEAR-END IS a time for reflecting on the successes and challenges of the prior year. For bankers, it is also a time to
complete various reports and reviews. The following is intended to help get you started on your own checklist.
It is not intended to be exclusive or to fit all situations. Many of the reports listed require use of year-end data.
Therefore, they will necessarily be prepared in January.
files are updated with current financials,
audits, SSAE-16, business continuity plans
and other data (as appropriate). Don’t for-
get to obtain current evidence of your ven-
dor’s liability insurance coverage including
General Liability, Auto Liability, Workers
Compensation AND Fidelity. If they’re
providing professional type services for
your bank (accountants, attorneys, secu-
rity companies, etc.) you should also ask
for evidence of their Professional Services
Liability/Errors & Omissions coverage.
• Review security devices and compli-
ance with Bank Protection Act. The
board should consider the adequacy of
the written security policy. Be sure you
are in compliance with the multi-factor
authentication requirements for online
banking and IVRs. The security officer
must report at least annually to the board.
• Perform Enterprise Risk Management
assessment.
• Measure inherent cyber risks and cyber-
security preparedness.
• ACH rule compliance audit. Be sure that
this is completed by December 1 each year.
• Red flag compliance report. An annual
compliance report is required by this
FCRA rule.
• Annual audit. Under the FDIC Improvement
Act of 1991, banks with $500 million
or more in total assets are required to
have an annual independent audit. An
• Year-end reports to IRS and customers.
There are a wide number of reports filed
on forms 1099 and 1098 reflecting inter-
est earned and interest paid, and W-2s
for employees, as well as other reports
such as property taken in satisfaction of
indebtedness, discharged debt, and the
like. The customers must receive their
reports by January 31 with the IRS receiv-
ing its report by February 28. Thus, the
bank’s data processing system must be
prepared to generate these reports at the
beginning of the year.
• Billing error resolution notices. Both
Regulation E and Regulation Z require
annual billing error resolution notices
or an alternative summary statement with
each periodic statement. Don’t forget that
this applies to payroll cards, too!
• Update and review appraisals where
appropriate. Don’t forget appraisals of
ORE.
• Review contingency plan, including elec-
tronic data processing arrangements. Be
sure that it includes pandemics like the
avian flu. The board should make sure that
this plan is current and meets the needs of
the institution as well as the requirements
of the pertinent regulations. Don’t forget
the Business Impact Analysis.
• Review third party vendor due diligence.
Remember that this is not a one-time
activity. Rather, be sure that your vendor
November/December 2017 www.ibat.org 7
independent audit committee of outside
directors should select the auditor. Smaller
banks may also desire an outside audit and
should select their auditor.
• Policies and procedures. Many banks
review and re-approve all policies and pro-
cedures annually. The best approach is to
update if there are changes in the laws or
regulations or in the bank’s products that
would necessitate such updates. Also, if
the board wishes to re-approve all policies
every year, then it is helpful to parcel these
out through the year rather than approve
all at once at year end!
• Training. Be sure that all required train-
ing has been accomplished for the year.
Directors should receive fair lending and
other training. Again, it is better to allocate
this throughout the year rather than attempt
to cram them all into year-end.
• Review correspondent relationships.
Review your exposure to correspondent
banks; obtain copies of correspondent
banks’ financial statements and evaluate
capital condition; set exposure limits.
• Record disposal/retention. Using an appro-
priate record retention schedule in line with
federal requirements, the bank should prop-
erly store records required to be maintained
and destroy records which have expired.
Remember that FIRREA has a 10-year stat-
ute of limitations on most crimes affecting
banking. Thus, some records will need to
be retained for a 10-year period. Also, the
Customer Identification Program and BSA/
AML regulations have some specific (mostly
five-year) record retention requirements.
(Texas law requires banks to retain check
information for seven years if statements
are truncated.) However, most records can
immediately be put on microfilm, micro-
fiche, or optical disk to reduce storage
needs. Update your program to handle
e-mail as part of your bank’s records. The
Dodd-Frank Act focuses on repayment abil-
ity with regard to residential mortgages.
Violation of this Truth in Lending require-
ment could create liability for the life of
the mortgage loan. Therefore, consider
updating your record retention schedule
to include maintenance of the underwriting
file.
• Set dividend to shareholders. The bank
board of directors should review its divi-
dend policy and its financial condition to
determine whether a dividend can legally
be paid under appropriate guidelines. If so,
then the dividend should be set aside for the
year with arrangements made for payment
to shareholders. This would also be a good
time to review, and, if necessary, change
your capital adequacy policy.
• Review schedule of fees and charges.
While this is not required by law, it is a
good idea to periodically review bank pric-
ing. This is a good time to consider your
pricing strategy for accounts. But don’t
limit this review to deposit account fees
and charges. Be sure that you have good
loan rate sheets. While these should really
be evaluated more frequently,
be sure that they are
updated at least annually
and are consistent with
fair lending practices.
• Annual personnel
evaluations. Again, this
is not required by law.
However, it is a good idea
to perform annual evalu-
ations of officers. (Annual
reviews of employees have
been going out of favor in
the HR community.)
• Year-end bonus.
Review incentive
compensation
and bonus
8 The Texas IndependenT Banker November/December 2017
programs. Check compliance with the mortgage anti-steering
rules in Regulation Z. MLO rules permit up to 10% of MLO’s
aggregate comp to include a non-deferred profits based plan (e.g.
year-end bonus).
• Review insurance coverage for adequacy. This includes not only the
directors’ and officers’ liability policy but also property & casualty
policies, trust and mortgage errors and omissions, workers’ com-
pensation, and the entire range of appropriate insurance coverage
for the institution.
• Review pension plan and take appropriate actions for the year. If
your bank has a pension plan, the plan committee should meet and
review investments as well as other reporting requirements for the
year.
• Holidays. National banks have the ability under federal law to
either abide by or ignore state holidays. State banks have the
same flexibility. The board of directors should set the holidays
by resolution. The best time to do this is at the December meet-
ing for the next calendar year. You may wish to use the Federal
Reserve holiday calendar. Be sure to decide whether Saturdays
and Sundays will be holidays, limited banking days, or full service
days.
The Federal Reserve standard holiday schedule mandates that
if January 1, July 4, November 11, or December 25 falls on a
Sunday, the following Monday will be observed as a holiday.
If January 1, July 4, November 11, or December 25 occurs on a
Saturday, the preceding Friday will not be observed as a holiday.
• Review and update CRA Notice and Statement. Note: A CRA Statement is not required by the regulations. If you choose to include one in your public file, do so for the benefit of community requestors—not the examiners.
• Prepare statement of bank policy with regard to civil rights and consumer compliance.
• Review and approve security policy. Appoint security officer.
• Review and approve emergency preparedness plan.
• Review and approve Affirmative Action Plan for EEOC (written plan is necessary if 50 or more employees). For other banks, consider adopting diversity policy and statement with regard to women and minority employees and vendors. Currently, this is voluntary.
• Review insurance coverage, including:
• Automobile (Owned, Hired & Non-owned or Repossessed)
• Workers Compensation
• Bankers Blanket Bond (Fidelity)
• Comprehensive General Liability
• Excess Liability (umbrella)
• Directors and Officers Liability (including Company Reimbursement and Entity Coverage)
• Bankers Professional Liability including Lender’s Liability
• Trust Department Errors & Omissions
• Fiduciary Liability
• Employment Practices Liability – including 3rd Party Harassment
• Mortgage Protection / Mortgage Impairment / Mortgage E&O
• Safe Deposit Liability and if desired, Protection for Customer’s Property in Safe Deposits
• Data Processing Equipment – damage to owned or leased equipment – hardware & software, including damage by virus
• Cyber Liability – damage to 3rd parties due to your electronic transmissions
• Property Insurance for Owned Bank Premises (including buildings, contents, ATMs, motor banks, etc.)
• Valuable Papers & Records
• Fine Arts
• OREO – Owned Real Estate – foreclosures for property AND liability exposures to loss
• Force Placed Insurance – real estate as well as other loan collateral (autos, boats, etc.)
• Employee Benefits (e.g. group term life)
• Group Creditor
• Review audit
• Review regulatory exam(s)
• Approve appraisers, auditors
• Review and approve policies and procedures
• Appoint compliance officer and BSA/AML officer
• Organize board committee structure and fee structure
• Elect officers and approve salaries
• Update strategic plan
• Set correspondent bank exposure limits
• Review vendor relationships and updated due diligence
• Complete ACH rule compliance audit by December 1
continued on page 22
882746_First.indd 1 8/23/17 9:24 PM
Annual Board Meeting Checklist
November/December 2017 www.ibat.org 9
Take the Headache Out of Social Media Regulations with WatchDOG® Social ComplianceRONNIE A. MILLER BOARD CHAIR, IBAT SERVICES INC.
S E R V I C E S S P O T L I G H T
SOCIAL MEDIA PROVIDES companies the unique
opportunity to create meaningful relationships
with customers. During its infancy, such social
media sites as MySpace and Facebook were
regarded by many as a passing trend. Now the idea
that social media can still be considered a “phase”
is laughable, and more than a few naysayers are
scrambling to make up for lost time.
Because of its incredible popularity, social
media has opened a whole new world to compa-
nies hoping to capitalize on the exposure. Financial
institutions certainly have not been immune to
this digital push. However, certain regulations like
the FFIEC’s Social Media Risk Guidance, Truth in
Lending Act, GLBA and other regulatory guidelines
have tacked on additional requirements for social
media activity. This comes as no surprise, as banks
are one of the most highly regulated industries in
the United States.
While producing content around products and
services on social platforms offers proven rewards,
complying with the industry regulations surround-
ing them can be tricky. Promotional product infor-
mation, lending terms and various other posts—if
not carefully reviewed on a regular basis—have
the potential to trigger violations with dire conse-
quences ranging from fines to an enduring negative
brand image among customers.
Regularly engaging in a social media risk
assessment is the most proactive approach to
mitigating these compliance liabilities. Yet per-
forming routine assessments on your own can be
a costly operational burden. That’s why the solu-
tion, WatchDOG® Social Compliance from CSI, an
IBAT Endorsed Service Provider, has become an
industry standard.
WatchDOG Social Compliance enables banks
to remain compliant with the various social media
restrictions imposed by regulators. Catered to the
unique needs of the financial industry, WatchDOG
security software allows banks to easily manage
and maintain these compliance standards, which
saves time, money and concerns regarding poten-
tial legal and ethical risks.
While producing content around products and services on social platforms offers proven rewards, complying with the industry regulations surrounding them can be tricky.
Banks must pay close attention to what is com-
municated via social media, for both compliance and
brand reputation purposes. In addition, archiving all
social media interactions (whether it be Facebook,
LinkedIn, Twitter, etc.) is one of the most important
regulatory requirements with which to comply. Within
the WatchDOG solution, social media data is archived,
and institutions have the ability to produce instant
reports for managers, auditors, board members and
regulators.
Further, having the ability to track all social media
interactions using one program not only aids in com-
pliance, but also makes sense from a marketing per-
spective, as it lets institutions view and chart brand
reputation on all social media platforms. WatchDOG
allows users to search their brand or products on
social media to gauge brand reputation among users
from any Internet-enabled device.
Finally, the software provides for an approval pro-
cess to ensure all posts meet regulatory guidelines.
For those less familiar with social media platforms
and the strict regulations that surround them, compli-
ance can be a major, costly operational hardship. Find
out if CSI’s WatchDOG Social Compliance automated
platform can help your financial institution get the
most out of the social media conversation. ■
Ronnie Miller, board chair of IBAT Services Inc., is
president and chief executive officer of Community
National Bank in Hondo.
©iStockphoto.com/adventtr
T H E C O M P L I A N C E G U Y
(More) Final Rules on TRIDKELLY GOULART, CRCM CAMS CIA IBAT REGULATORY COMPLIANCE MANAGER
IN JULY, THE Consumer Financial Protection
Bureau (CFPB) issued final rules for TRID.
These “final” rules actually finalize the rules
proposed by the CFPB in July 2016. In the more
than 500-page release, the CFPB stated that
this final rule “memorializes the Bureau’s infor-
mal guidance on various issues and makes
additional clarifications and technical amend-
ments.” At the same time the CFPB issued this
“final rule,” it issued a proposed rule on the so
called “Black Hole” regarding a creditor’s ability
to issue a revised Closing Disclosure (CLoD)
more than four days before closing and issue
a revised CLoD within three days of a valid
changed circumstance – more on that below.
So what exactly was finalized and when are
these new rules effective? Let’s start with the
effective date – which for mandatory compli-
ance is October 1, 2018. However, creditors
are free to voluntarily comply 60 days after
being published (August 11, 2017) in the Federal
Register. Actions taken before October 1, 2018
that weren’t a violation under the original TRID
rules by lenders acting in “good faith” may
become a violation after October 1, 2018. And
I’m not sure why anyone would want to wait
until October 1, 2018 with a practice that cre-
ates uncertainty at best.
Back to what was “finalized.” The 560 pages
offer a great deal of comment and nuance for
creditors in general, and there are a number of
important points for community banks. Here
are the ones I found most relevant – some of
which may be addressed by a creditor’s forms
provider or platform processor, but compliance
officers should verify the changes in policies
and procedures.
• Clarifies that percentage disclosures are
rounded to three decimal places but no trail-
ing zeros to the right of the decimal place.
• Clarifies that a lender may issue a revised
Loan Estimate (LE) every time informa-
tion is updated, even if there is no changed
circumstance.
• As a corollary to the point above, the final rule
permits a creditor to use the initial LE as the
benchmark for tolerance comparison purposes
instead of intervening LEs and CLoDs.
• Clarifies that the expiration date requirement
for the LE is extended if the creditor offers a
longer period.
• Clarifies that if a lender does not provide a
Settlement Services Providers List, all related
charges will be subject to a 10 percent toler-
ance threshold.
• Clarifies that a revised LE or CLoD, as appli-
cable, must be issued when the rate is locked
even if there are no changes to the disclosed
terms and charges. In other words, terms and
charges are the same before and after the rate
lock.
• Clarifies that the Total of Payments (TOP)
disclosure does not include specified seller,
lender, or paid by other fees as disclosed in
the CLoD.
• Establishes that the TOP disclosure accuracy
tolerance is based on the finance charge toler-
ance – meaning an overstated TOP is accurate.
• Clarifies that for loans subject to the right of
rescission, only loan applicants are listed on
the LE and as borrowers on the CLoD – not
persons with rescission rights.
• Establishes that a creditor may offset fees and
charges disclosed on the LE and the CLoD if
Actions taken before October 1, 2018 that weren’t a violation under the original TRID rules by lenders acting in “good faith” may become a violation after October 1, 2018. And I’m not sure why anyone would want to wait until October 1, 2018 with a practice that creates uncertainty at best.
10 The Texas IndependenT Banker November/December 2017
November/December 2017 www.ibat.org 11 886613_Editorial.indd 1 9/25/17 7:01 PM
the creditor knows at the time it issues the
LE or CLoD that the seller will be paying
some or all of the fee.
• Clarifies that prepaid interest is included in
the Total Interest Paid (TIP) disclosures.
• Clarifies that a principal curtailment is iden-
tified as a “principal reductions.”
Proposed Rule on the “Black Hole”The so-called “black hole” is the issue
about a creditor’s ability to issue a CLoD
instead of an LE for changed circumstance
that may take place four days or more before
closing, and issue a revised CLoD if there is a
changed circumstance more than three days
before closing. Here is what the CFPB stated
in the proposal.
As noted above and described in the pro-
posal, proposed comment 19(e)(4)(ii)-2
was intended to clarify that the reference to
Closing Disclosures required by §1026.19(f)
(1) in existing comment 19(e)(4)(ii)-1 refers
to both the initial Closing Disclosure required
by §1026.19(f)(1) and to any corrected
Closing Disclosures provided pursuant to
§1026.19(f)(2). Although the Bureau recog-
nizes that the text of proposed comment
19(e)(4)(ii)-2 could plausibly be interpreted
as also removing the existing four-business
day limit for providing corrected Closing
Disclosures to reset tolerances, the preamble
to the proposal does not describe that the
Bureau intended such a change.
…snip
In particular, the Bureau recognizes that the
current rules may lead to circumstances under
which creditors might be unable to provide
revised estimates for purposes of resetting
tolerances where the Closing Disclosure has
already been provided and there are four
or more days between consummation and
the time the revised version of the disclo-
sures is required to be provided pursuant
to § 1026.19(e)(4)(i). The Bureau believes,
however, that before finalizing a rule that
addresses this issue it is advisable to propose
more explicit language and to seek comment
so that stakeholders who understood the pro-
posal in accordance with the Bureau’s intent
will have the opportunity to provide their
perspectives on this issue.
While this is only a proposal, it appears
that based upon the language above, the
CFPB never intended for creditors to be
able to issue a CLoD instead of an LE for
changed circumstance that may take place
four days or more before closing, and issue
a revised CLoD if there is a changed circum-
stance more than three days before closing.
The “black hole” proposal issued with
the TRID final rule does provide that “under
the current proposal, creditors could use
either initial or corrected CLoD to reflect
changes in costs for purposes of deter-
mining if an estimated closing cost was
disclosed in good faith, regardless of when
the Closing Disclosure is provided relative
to consummation.”
There you have it – until the next set
of “final” rules. If you have any questions,
comments, or concerns, feel free to email
me at [email protected]. ■
Kelly Goulart, CRCM CAMS CIA, is IBAT’s regu-
latory compliance manager. Contact him at
512-275-2231 or [email protected].
12 The Texas IndependenT Banker November/December 2017
Edwin Edward Zapalac, 88, of Flatonia passed away on August 16, 2017.
Zapalac served in the U.S. Navy for four years during the Korean War. He
graduated from Corpus Christi College Academy and received a Bachelor
of Business Administration from North Texas State College (now UNT).
He worked for Flatonia State Bank, Central Texas Bank and State Bank
for 48 years, serving as president for 20 of those years. Zapalac was
actively involved in his community and in the banking industry, supporting
Independent Bankers Association of Texas and Texas Bankers Association,
and he was a founder and was acclaimed to have put the “z” in Flatonia’s
annual festival, Czhilispiel.
Zapalac is survived by his wife of 60 years, Gretchen; sister Jeanette
and her husband Ervan Zouzalik; sister Mary Ann and her husband Victor
Tichacek; daughter Renee and her husband Kenneth Pavlica; daughter
Beverly and her husband Kenneth Ponder; son Thomas and his wife Melodye
Zapalac; son David Zapalac; and son James and his wife Melissa Zapalac. He
is also survived by numerous grandchildren, great-grandchildren, nephews,
nieces, other family and friends.
John Currie, 86, of Big Spring, died August 24, 2017.
Currie graduated from Texas Christian University in
1951 with a business degree and completed the School
of Banking Program from the University of Wisconsin in
1957. He was employed by The State National Bank of Big
Spring for more than 60 years. He was active in a number
of banking organizations and was an organizing director of
Texas Independent Bank in Dallas and IBAT Bond Trust in
Houston. Currie was also active in numerous community
organizations through the years. Where tax money was
spent, he was never reluctant to speak up against fiscally
imprudent proposals.
Currie is survived by his wife of 65 years, Ruth of Big
Spring; four children, Carol, Bob, Henry and Tom; seven
granddaughters; seven great-grandchildren; and sister, Ann
McComb of Austin. He was preceded by his parents and
two grandsons.
N E W S
In Memoriam
Centennial BANK Donates Bank Building to City of PlainviewCentennial BANK announced that it will donate its banking center in
downtown Plainview to the City of Plainview. The 43,000-square-foot,
multi-million dollar building will house all of the city’s municipal services
under one roof. Centennial BANK will continue to operate out of the
facility while a new, state-of-the-art community banking center is built.
“This is an exciting day for Centennial BANK, our employees and the
City of Plainview,” said Matt Kelley, Centennial BANK Panhandle and
South Plains market president. “This community has supported us since
1934, and we are ecstatic to be able to reinvest in Plainview by making a
contribution of this magnitude to the city and the citizens.”
Discussions between Centennial BANK leadership and City of
Plainview officials began in 2012. City officials had been exploring
options to consolidate their municipal operations into one build-
ing. Banking operations will continue as usual for now at the
downtown banking center while plans for renovation, construction
and relocation continue between the BANK and city officials. The
building’s transition from Centennial BANK to the City of Plainview
is not expected until the fall of 2018.
IBC Named to Forbes Most Trustworthy Financial Companies List
Forbes named International Bancshares Corporation (IBC), an approxi-
mately $12 billion multi-bank financial holding company based in
Laredo, one of “America’s 50 Most Trustworthy Financial Companies”
in a survey commissioned by the magazine. With an Aggressive
Accounting and Governance Risk score of 92 out of a possible 100
and an average score of 88 over the last four quarters, IBC made the
same list in 2012 and 2014.
“International Bancshares Corporation is proud of its long history
of success, which has inspired confidence among its customers and
shareholders,” said Dennis Nixon, International Bancshares Corporation
chairman. “We appreciate that Forbes recognizes International
Bancshares as one of America’s most trustworthy financial companies.”
IBC Bank and Commerce Bank are divisions of IBC, with 192 facili-
ties and more than 297 ATMs serving 87 communities in Texas and
Oklahoma. In 2016, IBC celebrated its 50th anniversary. IBC Bank’s
slogan, “We Do More,” reflects the bank’s dedication to the growth
and success of both its customers and the communities it serves. IBC
was ranked 46th on Forbes’ 2017 list of “100 Best Banks in America.”
November/December 2017 www.ibat.org 13
Banker’s Toolbox Launches Due Diligence Manager
Commerce Street Capital Supports Small Business
PULSE Study Finds Debit Fraud Loss Rates Decline
Banker’s Toolbox, Inc. recently launched
its Due Diligence Manager solution for
beneficial ownership. This extension of
the existing BAM+ platform includes fea-
tures such as a flexible question builder
and automated periodic risk reviews.
“Beneficial ownership as the ‘fifth pil-
lar’ for anti-money laundering programs
represents the most significant regula-
tory challenge to community financial
institutions since the USA PATRIOT Act in
2001,” said John Meyer, Banker’s Toolbox
chief product officer. “It is our role as
compliance partner for our family of
customers to assist in these challenges.”
Due Diligence Manager can be
deployed both within the Banker’s
Toolbox BAM+ solution or as a stand-
alone solution to meet the requirements
of beneficial ownership. Banker’s Toolbox
also provides consulting services for
Customer Due Diligence business pro-
cesses, policies, procedures and calibra-
tion. All covered financial institutions are
required to comply with the final rule by
May 11, 2018.
The 2017 Debit Issuer Study, commissioned by PULSE, found that
U.S. financial institutions substantially increased issuance of chip
debit cards in 2016 and experienced reduced fraud losses. Since the
fraud liability shift for debit transactions took effect in 2015, around
80 percent of U.S. debit cards have been converted to chip cards.
Results also show that fraud loss rates dropped by nearly 30
percent, although it continues to be a challenge with an estimated
$900 million in debit card fraud in 2016.
“The financial services industry has taken a number of measures that
likely impacted the reduction in fraud losses for debit card issuers – includ-
ing conversion to chip debit cards, greater use of tokenization in mobile
commerce and continued investment in fraud-mitigation solutions,” said
Jim Lerdal, PULSE vice president of fraud and risk management. “It is a
balancing act because declining potentially fraudulent transactions could
lead to ‘false positive’ fraud identification, which can frustrate account
holders and potentially drive them to other methods of payment.”
Commerce Street Capital, LLC and the Small Business Investor Alliance (SBIA) gained
two wins with the unanimous U.S. House of Representatives passage of the Small
Business Investment Opportunity Act and the Investing in Main Street Act. Both bills
will strengthen the Small Business Investment Company (SBIC) program and increase
the amount of capital available for investment into small businesses. Commerce Street
Capital has raised more than $757 million for SBIC funds in seven years.
“Commerce Street has and will continue to serve an instrumental role in working
with the SBIA on the bills,” said Bobby Hashaway, Commerce Street Capital executive
vice president and chief operating officer. “Many of our banking clients have a strong
interest in supporting small business funding by making greater investment commit-
ments to SBICs, but have been constrained by an outdated statutory cap within the
Small Business Investment Act of 1958.”
In 2016, Texas-based businesses that received SBIC financing supported nearly
11,000 employees. Additionally, SBICs have invested more than $2.9 billion in Texas
over the last 10 years.
JMFA Approved as Registered CPE SponsorJohn M. Floyd & Associates (JMFA) has been certified by the National Association of
State Boards of Accountancy to be a sponsor of continuing professional education (CPE)
through the JMFA Academy.
All Academy sessions are free and offered exclusively to JMFA Overdraft Privilege®
clients at the company’s Houston training facility.
Through the Group-Live sessions, Academy attendees receive effective strategies
for maintaining compliant overdraft practices, and improving performance and service
results. Upon completion, industry professionals can receive up to nine hours of CPE
credit toward maintaining their professional certification level.
“Continuing education programs through the JMFA Academy are designed to provide
our clients with high-quality professional development and instruction to help them
improve performance and increase accountholder satisfaction through a fully compli-
ant overdraft service,” said John M. Floyd, JMFA chairman and chief executive officer.
“To reflect our commitment to excellent training and client support, all sessions are
facilitated by the company’s foremost overdraft program compliance and implementa-
tion experts.” ■
C O V E R S T O R Y: M E E T J O E K I M K I N G
Kim has been a long-time supporter of IBAT, and in October he was elected to chair the
association for 2017-2018. In this article we get to know a little about our new chairman and
his thoughts on the future of IBAT and the banking industry in general.
IBAT: So, Kim, tell us about the King family.
King: My wife Robin was raised in Brownfield, Texas and I was raised in Brady. We met
while attending Texas Tech University and married in 1976. We then moved to Bryan/College
Station, where Robin received her undergraduate degree and I completed my masters. I have
worked in banking since 1980 and Robin is a retired schoolteacher.
We have three sons: Riley, born in 1980; Montie, born in 1985; and Brantley, born
in 1989.
IBAT: Describe how you arrived at Brady National and expanded to other Texas locations.
King: After college, we moved back to Brady in 1980 and I took a job at Brady National
Bank. In 1984 we moved to Lockney, where I took a job with the First National Bank in
Lockney. In 1987 I was transferred to the First National Bank of Plainview. We returned to
Brady in 1994, and I went back to work at Brady National.
We were fortunate to be able to purchase the Brady National Bank — becoming the major
stockholder — and I became president & CEO. We acquired a Bank of America branch in Brady,
including the building which we sold. It is now occupied by the City of Brady. We acquired the
First National Bank of Ballinger in 1997. In 1999 we had the opportunity to acquire Citizens
Bank, Knox City, which included a branch in Abilene. We flipped the charter to establish the
main bank in Abilene and branch in Knox City. In 2004, we established the Bank of San Angelo
as a branch of the First National Bank of Ballinger. Also in 2004, we purchased the National
The Man Behind the MaskJoe Kim King, Brady National Bank
14 The Texas IndependenT Banker November/December 2017
JOE KIM KING, like so many other IBAT members, is a banker and a
rancher. Kim’s father was a rancher and veterinarian, and Kim planned
to follow in his footsteps. He received his Bachelors in Animal Science
from Texas Tech University (where he also served as a masked rider,
the school’s mascot). After earning his Masters in Agriculture from
Texas A&M University, Kim decided to pursue a career in banking.
American Bank in Uvalde (and renamed it
Uvalde National Bank).
We sold the Citizens Bank in 2009, and sold
the Uvalde bank in 2013.
Most recently in 2013, we expanded into
the Fort Worth market with a loan production
office, FNBB Texas, with my oldest son Riley
as president.
The banks in our holding company, Texas
Country Bancshares, Inc., currently have com-
bined assets of $265 million.
IBAT: How would you define your bank’s
culture and mission?
King: “Satisfying Needs and Building
Relationships” best defines our mission. Our
culture is built around personal service, a will-
ingness to help anyone who walks in the door
and a desire to do what is in the best interest of
our customers or prospective customers. We
have developed a banking family environment
with an inherent goal of delivering excellent
service in a friendly fashion. In addition, we
make it a priority to support our community
in every way we can and incorporate this
objective into our marketing strategy.
IBAT: Describe the Brady market and how
that has influenced your loan portfolio.
King: The Brady market is fairly stable
and typical of a rural market. We have two
industries that are influenced by the oil and
gas industry: the frack sand mining compa-
nies and a local drilling rig manufacturer.
Real estate is our largest concentration,
with available housing limited and a size-
able recreational real estate influence, and
that includes absentee ownership.
Hunting is a big seasonal market that
has a positive impact on sales tax revenue.
Agriculture continues to be a part of our
economic base, although there are fewer
production operators due to consolida-
tions and increase of absentee owners for
recreational use. The current construction
of the wind farm generation project has
increased economic activity and put pres-
sure on housing availability. Our loan portfolio
has been supplemented by loan participations
from our other market locations.
IBAT: Your loan to deposit ratio averages
around 50 percent. Is that indicative of mar-
ket loan demand, competition, conservative
philosophy, or all of the above?
King: We do have strong competition in
our rural market, with one other bank’s main
office located in Brady and a farm credit bank
office to cover this area. Fortunately, our com-
petitors are very competent and follow sound
lending activities. One important reason we
chose to expand our footprint into other
markets was to grow our loans system-wide.
The key to accomplishing this goal is hav-
ing well-qualified individuals managing our
banks, branches and LPO. We are all proactive
risk managers and develop our relationships
carefully, focusing on effectively meeting the
needs of our clients. This includes our rela-
tionship with TIB-The Independent Bankers
November/December 2017 www.ibat.org 15
We have developed a banking family environment with an inherent goal of delivering excellent service in a friendly fashion. In addition, we make it a priority to support our community in every way we can and incorporate this objective into our marketing strategy.
King and his wife, Robin.
A rare photo of the Texas Tech mascot holding Reveille, the Texas A&M mascot, in 1975.
King’s sons Brantley, Riley and Montie.
King and his sons working the ranch in McCulloch County.
16 The Texas IndependenT Banker November/December 2017
Bank, which provides tremendous support in many areas, including
loan participations.
IBAT: It looks like the bank is fairly active in the mortgage (1-4
family) market. How have the new regulatory compliance pressures
affected your ability to make these loans?
King: Since real estate is an important part of our portfolio we
had no choice but to adapt to the increased regulatory burden on real
estate loans. Compliance costs have certainly increased as with most
banks that have continued making real estate loans. The burden of
increased regulation has been a phenomenon since the beginning of
my career. With each downturn of the economy, the normal reaction
by our legislative bodies is to create more regulations.
Unfortunately, there has been very little bifurcation of regula-
tion between too-big-to-fail banks and community banks. Increased
regulatory burden is a normal trend in banking, but the implemen-
tation must be modified to fit the size of the bank and the markets
banks serve. I believe that some legislators are beginning to realize
the negative impact excessive regulations can have on community
banks and the economy.
IBAT: What do you say to the so-called experts who say that com-
munity banks with less than $250 million in assets are an endangered
species?
King: I hope they are wrong and I believe it is obvious up to this
point that it is not true. Consider the many reports of the mega banks’
inability to control inappropriate actions of their employees and
abuse of their customers on a large scale. Community banks have
consistently practiced the theme of “know your customer” for years
and take to heart doing what is best for the customer.
IBAT: You are obviously a busy man...banking, ranching, service
to TIB and now to IBAT. How do you effectively manage all the balls
you have in the air?
King: The key is setting priorities, with the most important being
to develop and maintain a team of dedicated and competent staff. I
realize there is no way I can do all the heavy lifting and I must depend
on others to do their part to manage all that we need to accomplish. I
must be diligent in scheduling and avoid trying to control everything.
I trust my team to support me in all that we have responsibility for.
Total control can be an addictive habit that leads to destruction.
There is no substitute for good help and we are fortunate to have
such a fine group committed to doing their job. And I must make
special mention of my family for the sacrifices they make to allow
me to pursue my interests.
IBAT: What would you say your top three priorities are as you
assume the chairmanship of the nation’s largest state community
bankers’ association?
King: At this point I am still trying to sort out the priorities I believe
to be in the best interest of IBAT. There are several that I have in mind
that are critical to the future of IBAT and the association’s continued
representation of community banking.
As in our own banks, succession must be a serious consideration
with proper due diligence and research to set the stage to make the
right decision in filling the position of president and CEO. The objective
IBAT’s board must accomplish is selecting the best candidate to carry
on the remarkable leadership and accomplishments of Chris Williston.
I also believe that the expansion of IBAT’s compliance support
to community banks across the nation is a great opportunity for our
IBAT team of compliance specialist to provide a valuable service to
our industry.
We should all have legislation and regulation as a priority. It is one
of the areas of greatest concern to me and we must continue to utilize
the influence developed over the years by Chris, Steve and their team
members, along with the IBAT membership, to improve the working
environment for community banks.
IBAT: Complete this sentence: My years as chairman will be labeled
a complete success if we ...
King: … accomplish the goal of deregulation. Not just a few adjust-
ments but a complete overhaul of the current plethora of unwarranted
regulatory burden.
IBAT: I know you are not a personal fan of the legislative process,
but you understand the necessity in engaging in the process through
your own grassroots contacts and political action donations. What
would you say to other community bankers who sit out and don’t
engage in the process?
King: There is no good reason for not getting involved at some
level of participation in the political process that affects the welfare of
banking. I know all the excuses—I used them for years. If you expect
to have some influence on your future in banking, then do something
that could make a difference. Donate to the PAC, conduct a PAC drive
at your bank or business and get involved at some level. It is a lot
easier to ask for money and be involved if you are a giver. ■
Texas Country Bancshares, Inc. board of directors: Terry Keltz, Sue Owens, John Childers, Kim King (Chairman), Riley King, Kirk Roddie, Diane Scovell, Ray Dierschke, Eugene Kasberg, Greg W. Schwertner, and Mark Marshall.
King shows off his culinary expertise. The bank often uses its cooker to prepare ribs for community events.
HAVE YOU EVER been to the doctor where you’ve spent 45 minutes in the
waiting room, then 30 more minutes in the exam room, only to have the
doctor come in, quickly read your chart, say a few words and then write
a prescription? I have. Maybe the doctor diagnosed me correctly, maybe
not, but the chances of presenting a correct diagnosis could have been
increased if the doctor had better communicated with me.
When a patient visits a doctor for a
specific condition, the job of the doctor
is to properly diagnose what the medical
issue is, and then prescribe a treatment
that will address the patient’s needs. Aside
from simply observing symptoms, in order
to diagnose, the doctor should consider
the patient’s demographics and listen thor-
oughly to what he or she has to say.
Similar to a doctor’s approach to diag-
nosing a medical condition, when a bank
attempts to implement the most effective
compensation package for its key execu-
tives, they must analyze who they are trying
to compensate and discern what the most
effective strategy is for that individual.
Because every executive’s circum-
stances are different, there cannot be a
one-size-fits-all plan. As the old adage goes,
if the only tool you have is a hammer, the
whole world starts to look like a nail. Rather
than offering an executive an industry stan-
dard cookie-cutter plan, it is in the bank’s
best interest to properly diagnose the needs
and wants of the executive, then apply the
best solution to satisfy both the executive
and the strategic objectives of the bank.
Traditionally, Supplemental Executive
Retirement Plans (SERPs) or Salary
Continuation Plans have been the most
popular plans for community bank execu-
tives. These are top hat plans, reserved for
highly compensated employees, and are
designed to retain and reward those who
have contributed to the success of the bank.
Typically they begin payout at retirement
and provide an income to the executive for
a defined number of years into retirement.
The amount of the benefit can be a fixed
amount or a percentage of final salary. This
is a great benefit for executives in their fif-
ties and older, who have retirement on top
of their mind.
While these plans are still very effective
for top executives, younger executives may
have more pressing interests than retire-
ment income. For example, executives who
tend to be in the middle stages of life may
recognize the need for retirement security,
but there are other things they first need to
address. Someone like me, in their mid-40s,
would really love to have all questions about
retirement answered already. But my big-
ger priority at this stage of life is providing
a college education for my three children.
The flexibility of nonqualified deferred
compensation plans allows an individual
to determine specific dates in the future
to receive a payout. A properly designed
deferred bonus plan can schedule these
payouts at the dates that coincide with
the beginning of college for an executive’s
child, for example. These payments can
continue for each year a child is expected
to be enrolled in college. After those obli-
gations are met, the plan will continue to
defer bonuses for a future date, which will
most likely be the executive’s retirement.
Correctly diagnosing the executive’s great-
est need allows the bank to create a benefit
plan that will be a much greater retention
tool than simply offering the executive a
cookie cutter plan.
Millennials probably even require yet a
different approach. For these employees,
both retirement and college funding are
too far away to be an immediate concern.
Because these employees are in the begin-
ning stages of their professional lives and
are in the midst of paying off student loans
or purchasing their first home, executives
in this demographic typically tend to be
cash focused. Annual bonus plans meet that
need, but do nothing in terms of retaining
the executive.
In a 2016 Deloitte survey, 73 percent of
millennials said they plan to leave their
job within five years, and 44 percent plan
to leave within two years. If the bank has
found valuable millennial employees who
they need to retain as part of a succession
plan, an annual bonus is not sufficient. A
creatively designed deferred bonus plan
which delays the payment of bonuses for a
short number of years before payment can
solve this problem. If the employee leaves
they forfeit their deferred bonuses from the
last few years. This meets the employee’s
need of the cash compensation and the
employer’s desire for retention using the
carrot and stick approach that keeps the
employee moving forward and growing with
the bank.
When assessing the best elements of
the nonqualified benefit plan that best fits
your executive and your bank, there are
several options that allow for an effective
design that meet the objectives of both
parties. Will it be a defined benefit plan or
a defined contribution plan? Will it have an
incentive based element to it? Will it be paid
out at retirement or while the executive is
B E S T P R A C T I C E S
Diagnosing Your Executive Benefit NeedsROB BARTON
November/December 2017 www.ibat.org 17
18 The Texas IndependenT Banker November/December 2017
still in service with the bank, or a combi-
nation of both? There are many options to
choose from based on the assessed needs
of the employee. Banks often tier benefits
depending on what really motivates differ-
ent employees based on age, experience
and performance.
When prescribing an appropriate treat-
ment, a doctor should ask the patient sev-
eral questions about their condition, listen
to their responses and observe the patient
and their symptoms, in an attempt to dis-
cover what will work best. Likewise, employ-
ers should practice a similar process when
designing effective compensation packages.
Just as one medical treatment cannot heal
every patient, one compensation plan does
not fit all. By properly communicating and
finding out the needs of the employee,
employers can put themselves in a better
position to fairly compensate and retain
employees long-term. ■
Rob Barton is a managing consultant
with Bank Compensation Consulting.
He can be reached at 214-919-2927 or
880485_Whitley.indd 1 08/08/17 12:00 am
Exceptional IT. Real People. Bigger Purpose.
To learn more, call Brad Giddens, Business Development Executive, at 325-947-5560 or visit CalTech.com
Meet Kenny Floyd,Tier 3 Engineer and family farmer. When Kenny is not making sure his customers’ networks are running smoothly, you can spot him taking care of the farm that has been in his family since 1967.family since 1967.
Proudly endorsed byThe Independent Bankers
Association of Texas
Amazon Ate My Bank:One Man’s Vision for the Apocalyptic Future of FintechCHRISTOPHER L. WILLISTON, VI, CAE
F E A T U R E : F I N T E C H
For the last few decades, we’ve watched
our expectations of personal privacy slip
away, sacrificed to the convenience of tech-
nology. It’s been a classic “frog in the pot”
situation. A million little decisions along
the way have warmed us up to the idea of
allowing companies to track us everywhere
we go and in everything we do.
However, where and how we spend our
money is the one data point that has yet to
be fully exploited by those whose business
model is to know all there is to know about
you and me.
This financial data is the holy grail of
“big data” companies.
With new players coming out of the
woodwork each month, all focused on the
“disruption” of banking, many community
bankers are trying to figure out fintech com-
panies: What is their goal? And how do they
plan to separate you from the financial data
of your customers?
I don’t pretend to have all the answers,
but I’m watching this unfold as a student of
technology and an advocate of traditional
banking. If nothing else, I offer my unquali-
fied vision for the “end” to which financial
technology might be building.
Fintech isn’t about shiny apps, faster
loan application processing or new credit
modeling. The end goal of fintech is open
banking. Those other things are just a
means to an end.
What is open banking? It is banking free
of a central banking relationship.
There are those who believe the future
of banking ought to be free from the neces-
sary tie to traditional banks. They believe
that financial data ought to be something
AS COMMUNITY BANKERS, you sit on the last great untapped resource of the
big data era. And, while you might not fully appreciate it at this moment,
what happens to that data might just dictate the future of the community
in which you live.
20 The Texas IndependenT Banker November/December 2017
November/December 2017 www.ibat.org 21
that belongs to the individual and that you
and I should be able to own this data with
ultimate freedom to move about the market-
place selecting the financial services that
most meet our needs.
This means portability of my financial
life. It’s a freedom to move, not only my
money, but my financial history, with the
focus of optimizing my relationship with
those companies with which I decide to
do business. It’s a desire to control what I
give to whom, with the belief that doing so
will somehow benefit me (via customized
promotions and focused financial advice).
Clear as mud? Good. Let me illustrate
it further.
For many of us, our cell phone has
become a central and ever-present figure
in our lives. But, much of the power of the
cell phone is not necessarily in the device
itself. The cell phone isn’t the best part of
the experience (though we still shell out
hundreds of dollars for the hardware).
The power of the device is in its apps to
which the phone provides us access. That’s
where we get most of our value. The apps
are where the functionality of the device
is increased and expended exponentially.
Imagine now that your “banking rela-
tionships”—and, primarily, your deposit
accounts—are like your cell phone. They’re
important. They’re the center of your finan-
cial life. The bulk of your transactions and
profile of spending are identifiable by the
way that money flows to and from your
deposit account (assuming, of course,
that you don’t deal mainly in cash). But, as
important as your deposit accounts are,
they’re just a commodity. Like your cell
phone, no matter which model you buy or
from which manufacturer you buy it, the
core functionality is similar. The same is
true of your deposit accounts.
Now imagine that your deposit account
of record isn’t with a bank, but is, instead,
with a company—like Amazon/Google/
Apple (“A/G/A”)—that holds a fintech
“bank” charter.
From your central deposit relationship
with A/G/A, you begin to run your daily
transactions. Your payroll deposit goes
directly to your A/G/A account, from which
you pay your bills. You use the power of
Google’s new partnership with Walmart
or Amazon’s ownership of Whole Foods
to place your grocery order online, pay
using your A/G/A account and pick it up at
the curb of the store. You use peer to peer
money transfer to settle up with friends and
split the check.
Using your phone or some other device,
you pay at point of sale, instantly transfer-
ring money from your A/G/A account to
the account of that business, which has
chosen to set up their store for payment
using those platforms to avoid credit card
transaction fees. A/G/A was far too eager to
facilitate those transactions without cost
to get access to the transaction data of
the small business. Later, when they have
a good profile of the business, A/G/A will
leverage these small businesses’ cashflow
and transaction histories to qualify them
Fintech isn’t about shiny apps, faster loan application processing or new credit modeling. The end goal of fintech is open banking. Those other things are just a means to an end. What is open banking? It is banking free of a central banking relationship.
continued on page 22
22 The Texas IndependenT Banker November/December 2017
continued from page 8
For 2018, November 11 occurs on
a Sunday; therefore, the following
Monday will be observed as a holiday.
• Privacy Notices. An annual notice is no
longer required for banks that only share
information with third parties under the
statutory exceptions (e.g. to complete
transaction; respond to subpoena, etc.)
and the privacy policy has not been
changed.
• HMDA key dates. Review the key dates
timeline from CFPB for changes to HMDA
data collection. http://files.consumer-
finance.gov/f/201510_cfpb_hmda-key-
dates-timeline.pdf
• Exclusions. Some rules provide for small
bank exclusions based on activity. At year
end, check to make sure loan servicing is
still below 5,000 (for small servicer), size
of bank is still $2 B in assets (small bank
QM), and foreign wire activity is still 100
or fewer.
• Property tax compliance. If your bank
does not escrow for payment of prop-
erty taxes (whether on residential mort-
gages or commercial loans secured by
real or personal property), check for
property tax payment. Remind bor-
rowers of their obligations under their
loan agreement to protect the bank
from liens. An article with helpful pro-
cedures to consider can be found at
https://www.ibat.org/pdfs/2012/04/09/
tax-lien-lender-considerations.
Year-end is a time to look back on the
successes—as well as problems—of the
preceding year. Use this time, and the
reports required, to plan ahead for an even
better 2018. ■
Karen M. Neeley, in the Austin office of Kennedy
Sutherland LLP, is widely recognized through-
out the Texas financial institution community
in the areas of regulatory and compliance law.
Contact her at [email protected].
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for small business loan products (Amazon
has already done this, amassing $3 billion
in loans to more than 20,000 merchants
since 2011).
Much of what I’ve described thus far
covers just the basics of your financial life.
Now you begin adding various components
from many vendors, just as easily as you
add apps to your phone.
Perhaps you add a mortgage from
Rocket Mortgage or a personal line of
credit from a crowdsourced lending com-
pany. Maybe you self-select a personal
financial management tool which sits on
top of your A/G/A account to help direct
your spending. Need a longer-term savings
product? Add a CD from preferred partners
to get a better rate. A/G/A’s growing profile
of your financial life means these third
party “app” providers can better target
you with the products/services that align
with your needs.
For personal lending, A/G/A might make
loans directly or source the loans, bundle
them and securitize them for sale to individ-
ual “investors” who are looking for a higher
yield savings or investment opportunity.
By now you see how disruptive this
would be for community banking, as a flee-
ing deposit base undermines the ability
of those banks to make loans in their
communities.
For consumers, the end question for
consideration, of course, is whether this
transformation of our financial lives will
facilitate a safe and reliable banking system
for the good of American commerce.
Recreating/disrupting banking is an
interesting goal, but we must ask whose
good it ultimately serves: Customers? Small
businesses? Local economies? The national
economy? The global economy?
Just as technology is reshaping every
aspect of how we live, work and play, we
can’t let those who stand to profit define
the end goals. The debate on the future of
commerce and banking is as important as
any public policy debate currently facing
our nation because where we end up can
enhance or threaten the very places we live.
As an industry, our challenge is to look
forward to this future and engage in conver-
sation about where technology and public
policy are taking us.
As community bankers, you sit on the
last great untapped resource of the big
data era. Failure to engage in defending
that resource might just mean the “holy
grail” is stolen out from underneath you.
For the future of our industry, the good of
customers you serve and the communi-
ties in which you live, let’s make sure that
doesn’t happen. ■
Christopher L. Williston, VI, CAE (clwilliston@
ibat.org) is Executive Vice President of IBAT.
Get the Most Out of Your ModelAll of that is fine as far as it goes and is cer-
tainly adequate in helping to put a check-mark
in the many regulatory boxes requiring one. But,
if management stops there, it is failing to exploit
what can perhaps be an IRR model’s most valu-
able capability. That is, giving management the
ability to view the outcomes of contemplated
changes to strategies and tactics while they are
still being contemplated, rather than waiting to
experience the results after implementation. To
some degree, this concept has already crept into
the purview of regulators as they are strongly
recommending that modeling processes include
changes in the composition and volumes of
various deposit accounts while exploring the
potential effects of alternative funding sources.
This type of simulation is less about strategy,
which management controls, and more about
the consequences that higher interest rates may
bring to bear on depositor behavior. And that is
certainly something beyond anyone’s control.
But, what about the things that manage-
ment does control, or at least heavily influence?
For instance, ideas that might successfully
reach fruition if outcomes could be known, or
missteps that might be avoided for the same
reason. Suppose management is considering
offering borrowers a new type of loan prod-
uct with characteristics that may differ signifi-
cantly from what is currently available. While
no model will be able to determine how many
customers may or may not go for the new prod-
uct, performing simulations will allow decision-
makers to quantify the effects of various levels
of acceptance. Management now has a much
better understanding of the risk/reward bal-
ance, or imbalance, of trying something new.
What about a new kind of deposit product?
Maybe a new, longer C.D. that provides for
periodic rate adjustments. What if it brings in
$5M in new money? What if it brings in $50M?
How much do various volumes affect net inter-
est income in various scenarios? What happens
F E A T U R E : I N T E R N E T R A T E R I S K
Look Before You Leap:Using Simulations in a Decision-Making FrameworkLESTER MURRAY
OVER THE LAST several years, community bankers have become well aware
of the regulatory emphasis on, and requirements of, interest rate risk
(IRR) management. Throughout the current and persistent environment
of ultra-low interest rates, regulatory mandates have expanded to include
more stressful rate scenarios under which income is projected and capital
is valued. In addition, sensitivity testing (stressing) of various modeling
assumptions has now become part and parcel of routine risk-measuring
exercises. Another regulatory condition of these efforts is that they be
conducted on a static balance sheet. Quite reasonably, examining agencies
do not want to review reports in which interest rate risk could perhaps
be masked by simple growth or changes in balance sheet composition.
November/December 2017 www.ibat.org 23
©iS
tock
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o.co
m/D
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24 The Texas IndependenT Banker November/December 2017
to the duration of liabilities and the economic
value of equity? Much of the mystery surround-
ing these potential changes can be cleared up
with the performance of strategic simulations.
As community bankers know only too well,
they operate in an extremely competitive environ-
ment. It’s an environment in which adaption and
innovation is not only a good idea, it’s necessary
for survival. Change for the sake of change is sel-
dom beneficial and not all innovations bring about
the desired results. By taking advantage of your
IRR model’s ability to simulate other-than-static
outcomes, community bankers can have a better
chance of finding strategies that have the great-
est chance of success, and just as importantly,
identifying the ones that don’t. ■
Lester Murray joined The Baker Group in 1986 and
is an Associate Partner within the firm’s Financial
Strategies Group. He helps community financial
institutions develop and implement investment and
interest rate risk management strategies. Before
joining The Baker Group, he worked at two broker/
dealer banks in Oklahoma City and was also an
assistant national bank examiner. A graduate of
Oklahoma State University, he holds Bachelor of
Science degrees in finance and economics. Contact:
800-937-2257, [email protected].
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November/December 2017 www.ibat.org 25
CORPUS CHRISTI
Curtis Clark has been
promoted to treasury
management bank offi-
cer at IBC Bank-Corpus
Christi. In this position,
Clark will continue to
promote the commercial
and small business services offered by
the bank, including working as a customer
advocate for IBC Link, the bank’s online
business banking service. He is a U.S. Navy
veteran and has more than 15 years of
management experience. He is also a 2016
graduate of the Leadership Corpus Christi
program and was named one of Corpus
Christi’s “40 Under 40” in 2016.
DALLAS
Cody Yanchak has joined
CalTech as business
development executive.
Yanchak has worked
with community bankers
across the U.S. for over
ten years. He has a pas-
sion for helping businesses succeed and
building lasting relationships and looks
forward to helping community banks in
the Midwest remain independent and maxi-
mize their investments in IT. Yanchak stud-
ied business management at Sam Houston
State University.
FORT WORTH
Shawn Dillon has been
promoted to president of
Fitech Payments. Dillon’s
background in sales com-
bined with his knowledge
of the community bank-
ing industry has helped
him build the Fitech brand into a lead-
ing payments provider for community
banks. He was instrumental in negotiating
agreements which saw Fitech become the
endorsed merchant services provider for
Pennsylvania Association of Community
Bankers, Independent Bankers Association
of Texas, Community Banking Association
of Illinois, Western Independent Bankers
Association and Community Bankers
Association of Kansas.
P E O P L EP E O P L E
Michael Peterson, direc-
tor of sales for Fitech
Payments, has under-
taken responsibility
for oversight of IBAT’s
endorsement of Fitech’s
merchant services.
Peterson previously managed Fitech’s
partnership with the Community Bankers
Association of Illinois. He will work with
community banks in Texas to evaluate
their current merchant services program,
develop strategies to grow their revenue
and increase customer retention.
KILGORE
Michael Cozart of
the Citizens Bank
Woodlands Banking
Center has been pro-
moted to assistant vice
president and leader of
the bank’s credit analy-
sis team. Cozart has been employed by
the bank for three years. He previously
worked at Fidelity Investments where he
served in various roles including senior
fund accounting analyst. He received his
BBA degree in Finance from Texas A&M
University. In 2015, Cozart completed his
Commercial Credit Certification, receiving
the “Certificate with Honors” designation
from the University of Houston.
LONGVIEW
Texas Bank and Trust Company has
announced several promotions and
new hires.
Claude E. Henry has
been named president
of the bank’s Tyler mar-
ket. Henry joined Texas
Bank and Trust in 2010 as
executive vice president
and manager of its South
Broadway location. He holds a Bachelor
of Business Administration degree from
Howard Payne University in Brownwood
and is a graduate of the Southwestern
Graduate School of Banking at Southern
Methodist University in Dallas.
Gary Matesic has joined
Texas Bank and Trust’s
Frisco branch as senior
vice president, trust offi-
cer and regional trust
manager. Matesic holds
a Bachelor of Arts in
Accounting/Business Administration from
Thiel College and a Master of Science in
Taxation from Robert Morris University.
He is an Accredited Estate Planner (AEP®)
through the National Association of Estate
Planners and Councils. Matesic is currently
president of the Dallas Estate Planning
Council, serves on the Trust Schools
Advisory Board of the Texas Bankers
Association, is a member of the trust fac-
ulty for the Southwestern Graduate School
of Banking, and is a member and former
director of the Estate Planning Council of
North Texas.
Tim Bradford has joined
the Frisco branch of
Texas Bank and Trust as
senior vice president and
trust officer. He earned
a Bachelor of Business
Administrat ion in
Finance from West Texas A&M University.
Bradford is a Cannon Financial – Certified
Wealth Strategist; he holds Series 7, Series
66, and past Life and Health Insurance
Licenses; and is a graduate of the National
Graduate Trust School of Northwestern
University, Evanston, Illinois. He is a cur-
rent member of both the Dallas Estate
Planning Council and the Estate Planning
Council of North Texas.
Jannette Erts has joined
the staff of Texas Bank
and Trust as senior vice
president and trust officer
in the bank’s Frisco loca-
tion. Erts holds a Bachelor
of Science in Economics
from the University of Texas at Arlington,
and a Master of Business Administration
in Financial Services from the University
of Dallas. She is a CFP certificant, and is
a member of the Dallas Estate Planning
Council and the Financial Planning
Association.
26 The Texas IndependenT Banker November/December 2017
Anna Laughlin has been
promoted to vice presi-
dent at Texas Bank and
Trust’s Richardson loca-
tion. She is a portfolio
manager in the branch’s
lending area where she
analyzes, manages, and maintains a portfo-
lio of commercial, industrial, and commer-
cial real estate loans. She holds a Bachelor
of Business Administration in Finance from
Stephen F. Austin State University where
she was a member of Delta Zeta Sorority.
Elissa Barbosa has been
promoted to assistant
vice president at the
bank’s Richardson loca-
tion. Barbosa attended
Brookhaven College and
has worked in banking
and financial services for over 18 years.
Her primary responsibilities include assist-
ing the bank’s DFW regional manager and
executive lending staff, serving as mortgage
coordinator, and managing the day-to-day
operations of the branch’s credit adminis-
tration function.
Kim Campbell has been
promoted to assistant vice
president in the bank’s
Van branch. Campbell
began working with First
State Bank Van, now Texas
Bank and Trust, as a teller
in 1988. She is currently involved with con-
sumer, commercial, and real estate lend-
ing. A former licensed real estate agent,
she is a magna cum laude graduate of Tyler
Junior College with an Associate of Applied
Science degree in real estate.
Linda Brooks has been
promoted to trust officer in
the bank’s investment divi-
sion. Brooks has worked
in the banking industry
for 37 years and joined
Texas Bank and Trust in
2002. She most recently worked as a trust
administrator where she manages and main-
tains a portfolio of accounts consisting of
personal trusts, court created trusts, IRAs,
and estates. Brooks graduated from Kilgore
College with an Associate degree in Business
Administration. She is also a graduate of the
Texas Trust School and the Texas Graduate
Trust School in Dallas.
LUBBOCK
Berry S. Pigg has been
appointed branch presi-
dent of FirstCapital Bank
of Texas’ new Milwaukee
Avenue branch. Pigg is a
graduate of Texas Tech
University, where he earned
a B.B.A in Finance. He later attended the
Texas Tech Banking School and Southern
Methodist University’s Southwestern
Graduate School of Banking. With more than
30 years of banking experience, Pigg special-
izes in real estate and commercial lending
and has served in the Lubbock financial
industry since 1984.
Monty Long has been pro-
moted to executive vice
president and chief finan-
cial officer at Centennial
BANK. His responsibilities
will include the manage-
ment of financial reporting,
budgeting, internal audit, corporate gover-
nance, accounts payable, capital planning
and investments. Long began his banking
career in 1995 and joined Centennial in
2001. He holds a bachelor’s and master’s
degree in business administration from
West Texas A&M University and is a gradu-
ate of the Southwestern Graduate School of
Banking at Southern Methodist University.
Centennial BANK has added three new mem-
bers to its board of directors.
Patrick Freedle is a sec-
ond-generation CPA and
tax partner with Davidson,
Freedle, Espenhover and
Overby P.C., an account-
ing firm with offices in
Kerrville and San Antonio
with more than 25 professional staff. Freedle
graduated from Texas Tech University in
1987 with a BBA in Accounting. He is active
in his community, having served on several
non-profit boards and is in his third term as
a KISD school board member.
Kevin Hunter has over
17 years of experience in
real estate brokerage and
development and currently
serves as chief operating
officer and chief financial
officer at CSW Development.
Hunter specializes in both ground up develop-
ment and redevelopment, project planning,
acquisition, renovation, leasing and man-
agement. He graduated from the University
of Texas at Austin with a degree in Finance
and Accounting. He is a Certified Public
Accountant and licensed Real Estate Broker.
Brad Morrison gradu-
ated from the Air Force
Academy with a B.S. in
Management as well as the
rank of Captain in the U.S.
Air Force. He continued
his education at Southern
Methodist University where he earned his
Master’s in Telecommunication. Morrison is
the founder and CEO of Innove, a cyberse-
curity and technology consulting company
based in San Antonio.
MIDLAND
Lorena Brown has been
promoted to assistant vice
president of loan opera-
tions with Community
National Bank. Brown
joined the bank in 2016
and is a 2007 graduate
of the University of Texas at Arlington
with a bachelor’s degree in Business
Administration with a major in finance.
Sterling Swack has been
promoted to vice president
at Community National
Bank. Swack received
a Bachelor of Science
degree in Chemistry and
Engineering from Texas
Tech University. Previously a market vice
president at another bank, Swack has more
than five years of banking and commercial
lending experience in the Lubbock and
Odessa markets.
MOUNT PLEASANT
Molly Curl has been
appointed to the board
of directors of Guaranty
Bancshares, Inc. Curl has
worked for more than 40
years in the areas of orga-
nization, compliance, loan
review, loan servicing, policy development,
budgeting, and capital strategic planning.
Most recently she served as a financial
services advisory partner with Grant
Thornton LLP. In 2016, she was appointed
by Governor Greg Abbott to a six-year term
November/December 2017 www.ibat.org 27
on the Finance Commission of Texas. Curl
is a graduate of John Carroll University
with a B.S.B.A. degree in Finance and is a
Texas licensed Certified Public Accountant.
SHERMAN
Matt Brown has been
appointed president of the
Sherman loan production
office for Legend Bank.
Brown will handle commer-
cial real estate lending in
Sherman and surrounding areas. He has over
14 years’ commercial lending experience and
is a graduate of Stonier Graduate School of
Banking and completed the Texas Bankers
Association Management Development
Program. He received his MBA from the
University of North Texas and his BBA from
Austin College.
BOSTON, MA
Claiborne Kitchin has
become vice president of
global channel partner-
ships and alliances in the
commercial arm of S&P
Global Market Intelligence.
As part of this role, he is responsible for
all state banking association relationships
nationwide. He also handles redistribution
relationships and consulting and vendor
partnerships. Kitchin has been with S&P
for nine years and holds a B.A. in History
from the University of Virginia.
OKLAHOMA CITY, OK
Matt Harris, senior vice
president at The Baker
Group, has earned the
Chartered Financial
Analyst® designation
from the CFA Institute.
Harris joined the firm in 2007 as an
intern while attending the University of
Texas-Austin, where he earned a BA in
Government and Economics. In 2010, he
joined the firm’s Financial Strategies Group
at the home office in Oklahoma City, where
he works directly with bankers, examin-
ers, and auditors regarding fixed income
portfolio analysis and asset/liability
management. Harris is also involved in
the development and testing of Baker’s
proprietary bond accounting and interest
rate risk software. ■
28 The Texas IndependenT Banker November/December 2017
In conjunction with Professional Bank Services (PBS), IBAT offers
the best compliance training available. Programs on Deposit
Compliance, HMDA, Lending Disclosure, Loan Compliance, and
much more, are offered as well as Compliance Updates.
November 2017 29 ACH Processing Compliance, Dallas/Irving
30 ACH Processing Compliance, San Antonio
December 2017 18 Texas Deposit Documentation, Austin 19 Texas Deposit Documentation, Temple 20 Texas Deposit Documentation, Wichita Falls
C A L E N D A R S
IBAT EVENTS & SUMMITS
COMPLIANCE SEMINARSwww.ibat.org/events/seminars
November 2017 1-2 IT Security and Fraud Summit 2-4 Certified Community Bank Director Program, Dallas 5-10 Bank Lending Institute, San Antonio
December 2017 5 Home Equity Summit 6 FDIC Outreach Program, Austin 8 FDIC Outreach Program, Dallas
January 2018 15-17 Winter Summit, Beaver Creek, CO
February 2018 5-9 IBAT Regional Meetings
March 2018 5-8 IBAT Regional Meetings
May 2018 1-3 IBAT Congressional Visit
June 2018 14-16 Leadership Conference, San Antonio
September 2018 22-25 IBAT Convention, San Antonio
October 2018 7-12 Bank Operations Institute, Dallas
IBAT hosts the following webinars in conjunction with
Financial Education, Inc. For more information, visit
www.ibat.org/events/telephone-seminars, or contact Julie Courtney,
[email protected], 512.275.2227.
IBAT WEBINARSwww.ibat.org/events/telephone-seminars
November 2017 2 CECL Loss Estimation Methodologies: Using Your
Bank’s Data History to Create Workable Options
7 Required Compliance for Commercial Loans Secured
by Real Estate
8 Auditing for Regulation E Compliance
9 When a Depositor Dies: Next Steps & Best Practices
14 Federal Government ACH Payments: Reclamations &
Garnishments
16 Accepting Powers-of-Attorney on Deposit Accounts
21 Required Compliance for the Board & Senior
Management
28 OFAC Sanctions Compliance: Update, Expectations &
Best Practices
29 Robbery Preparedness for All Staff
30 Avoiding Employee Job Misclassification Issues:
Getting It Right!
December 2017 5 Job-Specific BSA Compliance for Lenders
6 Conducting a Collections Risk Assessment
7 Disaster Preparedness, Recovery & Business
Continuity
12 Mortgage Loan Disclosure Timing Issues
13 All About 1099 Reporting Part 2: Forms 1099-INT &
1099-MISC: Vendor Payments, Prizes & Interest on
Deposit Accounts
14 ACH Risk Management & Assessment: Risks, Controls &
Ratings
19 Preparation Plan for CDD Changes to Beneficial
Ownership Rules: Effective May 11, 2018
20 New Security Officer Training: Responsibilities, Best
Practices & Skill-Building Tools
SAVE THE DATES!IBAT 26th Annual Congressional VisitMay 1-3, 2018Washington, DC
Leadership ConferenceJune 14-16, 2018San Antonio
IBAT ConventionSeptember 22-25, 2018San Antonio
November/December 2017 www.ibat.org 29
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BANK OPERATIONS EQUIPMENT & SUPPLIESComCo Systems ��������������������������������������������������24 www�comcosystems�com
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LiftFund, Inc. Dan Lawless, Chief Lending Officer San Antonio, TX www.liftfund.com LiftFund is a financial and business-support non-profit company that helps diverse and underserved entrepreneurs strengthen their businesses, increase their incomes and revitalize their communities. Since inception in 1994, LiftFund has made over 19,000 loans totaling more than $250M. LiftFund is a certified SBA 504 and 7a CA lender.
N E W M E M B E R S
Optima Compass Group, LLC Jorge Guerrero, CEO Bee Cave, TX www.optimacompass.com Optima Compass provides anti-money laundering compliance software and solutions to financial institutions, regulators, and law enforcement agencies in the United States and abroad. Optima’s AML Compass compliance software is a full compliance suite that includes robust OFAC compliance capabilities.
Windstream Carri Carswell, Major Account Representative Austin, TX www.windstream.com Windstream is a Fortune 500 company that provides enterprise communication solutions to businesses nationwide. Our network solutions are tailor-made to support our customers’ strategy with expert local support. Our complete portfolio includes network and data services, voice and unified communications, network security, managed services and cloud services. ■
CONSULTANTSWhitley Penn ��������������������������������������������������������18 www�whitleypenn�com
FACILITIESPhaseOne Design Builders ��������� Inside Front Cover www�phaseonebuilders�com
INSURANCE PRODUCTS & SERVICESAmerican National Insurance Company ���������������������������������� Inside Back Cover www�anico-cid�com
IT SERVICESCalTech ����������������������������������������������������������������19 www�caltech�com
SECURITYComCo Systems ��������������������������������������������������24 www�comcosystems�com
30 The Texas IndependenT Banker November/December 2017
C O M M U N I T I E S
If you have
a photo to share,
email it to
July 24 – Woodforest National Bank gives $1 million gift to Houston Methodist The Woodlands Hospital; hospital names third floor common area – Woodforest Bank Sky Plaza. In late 2016, the bank committed $1 million to the new hospital to name its third-floor atrium space and support the hospital’s Excellence Fund. The fund advances the hospital’s highest priorities and accelerates innovative research and physician recruitment in key clinical areas.
September 18 – Chris Williston, IBAT president and CEO, and Julie Courtney, IBAT Education Foundation president, at the annual convention of the Texas Society of Association Executives in Houston. Courtney received the Professional Excellence Award from TSAE, which recognizes individuals who have made exceptional contributions to their association and demonstrate abilities for continued high levels of achievement in the field of association management. Courtney has worked for the Independent Bankers Association of Texas since 1999. She has also received her certified association executive and certified meeting planner designations. Photo courtesy of Kayla Prasek Photography.
September 17 – Christopher L. Williston VI, CAE, IBAT executive vice president, addresses attendees at the Texas Society of Association Executives annual convention in Houston. Christopher was elected to serve as TSAE chairman of the board for 2017-2018. He is the third generation of Willistons to hold that honor, following in the footsteps of his father and grandfather. Photo courtesy of Kayla Prasek Photography.
August 1 – IBC Foundation, administered by
International Bank of Commerce (IBC Bank),
donates $250,000 to University of the
Incarnate Word School of Osteopathic Medicine
(UIWSOM). The donation supports the development of UIWSOM in areas such
as the clinical skills lab for first- and second-year
medical students. Third- and fourth-year medical
students will benefit from the newly-formed
partnership with the Laredo Medical Center
for clinical rotations and residency programs
in family and internal medicine.
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