Legal Ease

We are confused. What is a ‘renewal’ vs. a ‘refinancing’ vs. a ‘modification’?

Learn the answer here.

Staff contact: Shannon Phillips, sphillips@ibat.org, 512-275-2221
Staff contact: Kelly Goulart, kgoulart@ibat.org, 512-275-2231

Legal Ease is chosen from questions received through the IBAT Compliance Adviser Helpline, available to IBAT members free of charge at 1-800-749-4228, kgoulart@ibat.org or sphillips@ibat.org. IBAT members can also read and/or initiate discussions with other community bankers in the IBAT Compliance Forum. The Legal Ease archives are also available on IBAT2GO, the official IBAT mobile app.

National Survey

According to the 2015 FDIC National Survey of Unbanked and Underbanked Households released last week, the share of the population that is unbanked continued falling in 2015. It reached 7 percent – down from 7.7 percent in 2013 and 8.2 percent in 2011 – the lowest share yet recorded in the biennial survey that has been conducted since 2009 by the FDIC and U.S. Census Bureau.

The study found that half of the ongoing decline in unbanked status can be attributed to economic improvements and as people become employed or grow their assets, they often enter or return to the banking system. Other findings show that major contributing factors to unbanked status include not having enough money to justify opening an account – more than one-third of the unbanked stated this reason. Twenty percent of U.S. households were unbanked or underbanked last year.

Highlights of the survey can be found here

Staff contact: Shannon Phillips, sphillips@ibat.org, 512-275-2221

Upcoming IT Security Summit

Cyber threats have become more sophisticated than ever and attackers are exploiting endpoints to gain access to your network’s most critical assets. Today's IT security officers have a lot to handlem, including:

  • Cyber threats,
  • Reputation risk,
  • Vendor management,
  • Risk assessments,
  • Social media,
  • Mobile payments and
  • Information security examinations.

IBAT is partnering with experts from the Federal Reserve Bank of Dallas, as well as Endorsed Service Providers SecureWorks and CalTech, to bring you the IT Security and Fraud Summit, November 9-10, 2016 in Dallas.  

The Dallas Fed will use current research to show attendees how the threat landscape has evolved and how advanced adversaries are now targeting endpoint security vulnerabilities. Click here to learn more and register.

Staff contact: Jessica Hernandez, jhernandez@ibat.org, 512-275-2207

CSBS White Paper

The Conference of State Bank Supervisors (CSBS) released a white paper describing the opportunities and benefits of shared resource arrangements. While the paper acknowledges that consolidation is an option banks can use to achieve economies of scale and more efficiently comply with regulations, it provides evidence that the same benefits may be achieved or exceeded through shared personnel or resources. For ideas on how banks might share resources, the authors provide examples of opportunities in information technology, regulatory compliance and expanded powers.

“As local banks continue to consolidate, the real losers are the residents, farmers, ranchers and small business owners of our small and rural communities,” said IBAT President and CEO Chris Williston. “The vacuum that is created when banks consolidate is often never filled or is partially filled by mega-banks, payday lenders and shadow lenders who are only seeking a profit and not truly interested in serving the community.”

IBAT is intrigued by the idea of shared resource arrangements and would like to know what you think. If you are with a small community bank, please take this one-question survey to express your thoughts on the idea – Shared Resource Arrangements Survey.

Staff contact: Shannon Phillips, sphillips@ibat.org, 512-275-2221

DOB Legislative Consideration

The Texas Department of Banking recently released its issues for legislative consideration for the 2017 session. This information was shared as part of the agenda for the upcoming Finance Commission of Texas meeting on October 21, 2016.

Included in the list of DOB legislative priorities are the following:

  • Provide that persons subject to prohibition orders may not serve as a director, officer or employee in state bank holding companies;
  • Prohibit felons from serving as an officer of a state bank or trust company; and
  • Provide Commissioner discretion for termination of supervision order.

The entire list can be found here. Additionally, the Department of Savings & Mortgage Lending’s items for legislative consideration can be found here.

“We appreciate the Banking Department, as always, giving us a heads up on its legislative priorities,” noted Steve Scurlock, IBAT Executive Vice President. “We look forward to working together throughout the 2017 session to help achieve these.”

Staff contact: Shannon Phillips, sphillips@ibat.org, 512-275-2221

IBAT Webinars

Did you know? IBAT, in conjunction with Financial Education, Inc., hosts close to 150 webinars a year. Webinars are a very economical way to train your staff for one low price. Everyone can sit in on the program with the use of a speakerphone and a computer, or access archived webinars on-demand.

Topics are broken up by category or by date and include:

  • Auditing & Accounting
  • Collection
  • Compliance
  • Directors
  • Frontline and New Accounts
  • Human Resources
  • IT
  • IRA
  • Lending
  • Operations
  • Security & Fraud
  • Senior Management

You can access a complete listing of upcoming webinars and archived webinars here.


The general election is finally here. Early voting started yesterday, October 24, and runs through Friday, November 4. Election Day is Tuesday, November 8. You can easily access early voting and Election Day polling locations, as well as sample ballots, by visiting your County Clerk's website or the Secretary of State’s website.  

The IBAT PAC and IBAT FedPAC have again been active this election cycle, thanks to the generous support of you and your community banking colleagues. We have historically followed the "friendly incumbent rule" and supported candidates with whom we've worked and established relationships.  

We also frequently get questions regarding judicial races from our members. We have a longstanding relationship with The Texas Civil Justice League (TCJL), one of the leading tort reform groups in Texas. TCJL endorses judicial candidates, and we encourage you to take a look at its endorsements

Please feel free to call or email Meredyth Fowler if you have any questions or comments, and please vote and encourage those in your circle of influence to do the same.

Staff contact: Meredyth Fowler, mfowler@ibat.org, 512-275-2245

Trump vs. Clinton

With early voting underway this week, it’s hard for many to look past the top of the ticket. The presidential election of 2016 has been anything but orthodox, with many still unclear just what a Clinton or Trump Presidency really means for the community banking industry. 

In an effort to answer that question, American Banker published separate stories last week, What a Clinton Victory Would Mean for Bankers and What a Trump Victory Would Mean for Bankers.

While Hillary Clinton has outlined a plan for regulatory relief for community banks, the article notes great cynicism among the publication’s readers that a Clinton administration would actively pursue such a plan. Rather, many in the industry believe that she’d allow Senator Elizabeth Warren to drive financial policy.

In contrast, the Trump article quotes one of his industry advisors as saying, "We haven't spent too much [time] on [financial policy] except for one issue and that is Dodd-Frank. He wants to roll it back." Over the weekend, Trump reiterated his belief that overregulation is killing many American businesses and proposing that any new regulation must require the elimination of two existing regulations.

"Regardless of one’s personal political preference, this will be a pivotal election for the future of our country and community banking," said IBAT President and CEO Chris Williston. "I encourage the entire IBAT family to get out and vote, and then work alongside us as we double down on our efforts to obtain meaningful regulatory relief in the next Congress."

IBAT members can receive FREE access to American Banker (a $1,575 value) through the association’s subscription block. To be added, please contact Alina Greavu.

Staff contact: Chris Williston, cwilliston@ibat.org, 512-474-6889

Salary Survey Results

The results of IBAT’s 2016 Community Bank Salary and Compensation Survey—the gold standard in community bank salary, benefits and directors’ compensation data—are now available. Key benefits of the Salary Survey include:

  • New in 2016: Expanded benefits section to provide insights into health insurance benefit trends in light of the continued implementation of the Affordable Care Act;
  • Only the top 25 most essential job positions to reduce your time commitment;
  • Consolidated data filtration parameters to yield larger data pools for more valuable customized comparison reporting;
  • Comprehensive static report of survey results and online custom reporting tool for peer comparisons; and
  • Targeted questions on bank employee benefits.

Pricing information can be found here. If you participated in the survey, you should have received your complimentary copy of the comprehensive PDF report and online access to our custom reporting tool. If you would like to order a copy, please contact Christopher Williston.

Staff contact: Christopher Williston, clwilliston@ibat.org, 512-275-2208

Baker Market Update: Oct. 24, 2016

Chicago may hold a 3-2 advantage over Los Angeles in the National League Championship Series, but that hasn’t prevented some fans from making preemptive charges of the games being rigged if the Cubs don’t make it to the World Series. No one wants any outside interference with the national pastime. While Americans were preoccupied with football season, baseball season, and Presidential election season, the European Central Bank (ECB) was busy trying to keep the fragile economy of the European Union afloat at this week’s policy meeting. Disappointed investors had hoped for clarity from ECB President Mario Draghi on the possible extension and maybe expansion of the current bond-buying program. Those investors seem to have forgotten that they’re dealing with a Central Banker.

Read More in the Baker Market Update

IBT Partners with Deluxe

IBT Partners with Deluxe

CEDAR PARK, TX – October 17, 2016 – IBT, Inc., and Deluxe Corporation, have joined forces to help community financial institutions drive greater financial performance.


In an agreement with Deluxe Financial Services, IBT will now offer Bankers Dashboard and Credit Union Dashboard (collectively Deluxe Performance Dashboard) to clients using i2Core. IBT’s i2Core helps financial institutions improve operations, reduce costs, and mitigate risks by providing the ability to view all client data and transactions in a real-time environment.


Financial institutions use Deluxe’s Performance Dashboard to monitor performance across a spectrum of indicators. This powerful web-based tool provides performance management information to all levels of the organization, facilitating transparency and encouraging collaboration among financial institution leaders.


“Performance management and forecasting are critically important in the current regulatory environment,” said Mark Dittman, CEO of IBT.  “As part of our commitment to delivering robust solutions to our customers, IBT sought a partner that would simplify the budgeting and forecasting process. With enhanced data visualization, the Deluxe Performance Dashboard provides outstanding financial reporting and analysis, and the data shows that Dashboard clients outperform the market on Net Interest Margin by an average 26bps over the past 3 years. We are excited to align ourselves with an organization with such impressive results.”


Both companies are dedicated to helping community financial institutions succeed. IBT places great value in partners that have demonstrated they can increase income for its financial institutions. Deluxe has demonstrated that they are a partner who meets this criteria.  By pairing the Deluxe Performance Dashboard with IBT’s i2Core, community financial institutions are positioned to drive additional income to the bottom line.  


“Deluxe Performance Dashboard is a critical tool that financial institutions rely on for timely performance metrics,” explained John Filby, president of Deluxe Financial Services.  “Working with IBT, we are able to provide our mutual clients with the right data and the platform to gauge real-time financial performance, enabling them to make necessary adjustments to ensure that their financial performance is optimized.”




About IBT

IBT is a true partner that strengthens relationships and enhances customer retention.  IBT’s Core processing with i2Suite is the right way to do business for you and your customers, reducing costs, improving efficiencies and enhancing compliance. i2Suite is a powerful and scalable solution that exemplifies the next generation of core processing and data management solutions. The innovative design lowers operating costs while creating a client solutions advantage. For more information, visit IBTapps.com.


About Deluxe Corporation

Deluxe is a growth engine for small businesses and financial institutions. 4.5 million small business customers utilize Deluxe’s service and product solutions, including website development and hosting, email marketing, social media, search engine optimization and logo design, in addition to our industry-leading checks and forms offerings. Deluxe serves approximately 5,100 financial institutions with a diverse portfolio of financial technology solutions that enable them to grow revenue and manage their customers’ throughout their lifecycle, including our best-in-class check program solutions. Deluxe is also a leading provider of checks and accessories sold directly to consumers. For more information, visit us at www.deluxe.comwww.facebook.com/deluxecorp or www.twitter.com/deluxecorp

HUD Funds for Texas

HUD Secretary Julián Castro awarded a total of $500 million to help Texas, Louisiana and West Virginia recover after severe flooding events that occurred earlier this year. Provided through HUD's Community Development Block Grant - Disaster Recovery (CDBG-DR) Program, these recovery funds will assist the most impacted communities that experienced the most serious damage to their housing stock.

Texas was awarded $45,200,000, and HUD will publish a notice in the Federal Register that will define the criteria for the use of these funds shortly. CDBG-DR grants can support a wide variety of activities, including housing redevelopment, business assistance and infrastructure repair.

Staff contact: Shannon Phillips, sphillips@ibat.org, 512-275-2221

Legal Ease

If an application is withdrawn or denied within three days of submission, does the bank have to provide the notice of the right to receive a copy of the appraisal under 1002.14(a)(2)?

Learn the answer here.

Staff contact: Shannon Phillips, sphillips@ibat.org, 512-275-2221
Staff contact: Kelly Goulart, kgoulart@ibat.org, 512-275-2231

Legal Ease is chosen from questions received through the IBAT Compliance Adviser Helpline, available to IBAT members free of charge at 1-800-749-4228, kgoulart@ibat.org or sphillips@ibat.org. IBAT members can also read and/or initiate discussions with other community bankers in the IBAT Compliance Forum. The Legal Ease archives are also available on IBAT2GO, the official IBAT mobile app.

2016 Bank Operations Institute


IBAT hosted its 36th Annual Bank Operations Institute (BOI) at Southern Methodist University (SMU) in conjunction with the SW Graduate School of Banking and SMU Cox School of Business on October 9-14, 2016. Sixty-seven community bankers from across the state attended the program, which offers strategic insight into the present and future of banking processes, project management, technology and cybersecurity.

Congratulations to the following class officers and top-performing students.

Level One Officers:

  • President Ryan Anderson from Woodforest National Bank in Conroe, Texas;
  • Vice President Amanda Hinsley from First National Bank of Floydada in Floydada, Texas; and
  • Secretary Joe Rudd from Marion State Bank in Marion, Texas.

Level Two Officers:

  • President Ryan Webb from Security Bank in Tulsa, Oklahoma; and
  • Vice President Katrina Grove from First Interstate Bank in Billings, Montana.

The top-performing students in level two this year were Joe Johnson from Western Bank in Coahoma, Texas; Greg Clayton from TIB-The Independent BankersBank in Dallas, Texas; and David Anderson from American Bank of Commerce in Wolfforth, Texas.

Learn more about BOI here, and contact us if you’re interested in the 2017 program.

BOI Level II Class BOI Level I Class


FS-ISAC’s latest report for community institutions offers tips on managing third-party risk. The report focuses on a Software Engineering Institute (SEI) white paper titled Managing Third-Party Risk in Financial Services Organizations: A Resilience-Based Approach that encourages community institutions to focus on essential activities and risks, identify key cybersecurity requirements, ensure end-to-end processes and more.

Staff contact: Shannon Phillips, sphillips@ibat.org, 512-275-2221