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KENTUCKY BANKER

INSIDE

Straight Talk: Dodd-Frankenstein p. 6 Is Kentucky the Silicon Valley of Hemp? p. 8 Chairman’s Cup Clay Shoot p. 5/10/11

August 2015


OFFICERS

BOARD OF DIRECTORS

CHAIRMAN Mr. H. Lytle Thomas Heritage Bank, Inc.

Mr. Bill Allen Bank of the Bluegrass and Trust Company

VICE CHAIRMAN Mr. Louis Prichard Kentucky Bank

Mr. William Alverson Traditional Bank, Inc.

Mr. Glenn Meyers Kentucky Federal Savings & Loan Association

Mr. James W. Beach Peoples Bank & Trust Company

Mr. Michael Mineer Citizens Deposit Bank & Trust

Mr. J. Wade Berry Farmers Bank & Trust

Mr. Thomas J. Smith, III American Bank & Trust Company, Inc.

TREASURER Mr. Michael H. Mercer First Security Bank of Kentucky PAST CHAIRMAN Mr. Neil S. Bryan The Farmers Bank of Milton

Mr. William F. Brashear, II Hyden Citizens Bank Ms. Lanie W. Gardner First Southern National Ms. Elizabeth Griffin McCoy Planters Bank, Inc.

Mr. Gordon Kidd United Cumberland Bank

cover photo by

Linda Shelley “Kitty”

Mr. Ryan Steger Town Square Bank Mr. Frank B. Wilson Wilson & Muir Bank & Trust Company Mr. Greg A. Wilson The First Commonwealth Bank

from scenes of kentucky photo contest

KBA STAFF Ballard W. Cassady Jr. bcassady@kybanks.com President & CEO Debra K. Stamper dstamper@kybanks.com EVP / General Counsel / Director of Compliance

Michelle Madison mmadison@kybanks.com Information Technology Manager Lanie Minton lminton@kybanks.com Administrative Assistant

Paula B. Cravens Sturgeon Katie Rajchel krajchel@kybanks.com pcravens@kybanks.com Staff Accountant Director of Education Solutions Yvonne Savage ysavage@kybanks.com Selina O. Parrish PAC Services Coordinator sparrish@kybanks.com Director of Vendor Angie White Solutions awhite@kybanks.com Manager, Communications Matthew E. Vance Solutions / KBM Editor mvance@kybanks.com Chief Financial Officer Steve Whitlow swhitlow@kybanks.com Miriam Cole Systems Engineer mcole@kybanks.com Executive Assistant Paula Cross pcross@kybanks.com Education Services Coordinator Jamie Hampton jhampton@kybanks.com Education Services Coordinator

CONSULTANT

John P. Cooper jcooper@kybanks.com Legislative Solutions

HOPE OF KENTUCKY Billie Wade bwade@kybanks.com Executive Director

Tammy Nichols Natalie Kaelin tnichols@kybanks.com nkaelin@kybanks.com Finance Officer & Asset Assistant General Counsel Manager

KBA INSURANCE SOLUTIONS Chuck Maggard cmaggard@kybanks.com President & CEO Brandon Maggard bmaggard@kybanks.com Account Representative Audrey Whitaker awhitaker@kybanks.com Insurance Services Coordinator Tim Abbott tabbott@kybanks.com Account Representative Lisa Mattingly lmattingly@kybanks.com Director of Sales & Service Donna McCartin dmccartin@kybanks.com Benefit Support Specialist

CONTACT KENTUCKY BANKER MAGAZINE Angie White, Editor awhite@kybanks.com

CONTACT THE KBA

600 W. Main St., Suite 400 Louisville, KY 40202 Phone: 502-582-2453 Fax: 502-584-6390

Kentucky Banker magazine is a monthly periodical publication of the Kentucky Bankers Association. Published in Louisville, Kentucky.

One Voice, unifying Banking in the Bluegrass Welcome to the KBA, a nonprofit trade association that has been providing legislative, legal, compliance and educational services to its member institutions since 1891. KBA’s directors and staff work together with its members to make the financial services industry a more effective and successful place to work. The strength of the KBA is bankers unifying as an industry to speak as one voice.

Mission Statement The purpose of the Kentucky Bankers Association is to provide effective advocacy for the financial services industry both in Kentucky and on a national level; to serve as a reliable and responsive source of information and education about areas of interest to the industry; and to provide a catalyst and forum for collective industry action. The KBA does this in four ways: 1. Government relations and industry advocacy 2. Information interchange 3. Education 4. Products and services


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MANAGING PRINCIPAL

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(BCP) is a national leader in the design, implementation, and administration of Bank-Owned Life Insurance (BOLI). We are endorsed by the Kentucky Bankers Association and have earned the trust of more Kentucky community banks than any firm in the country. So when you want the best for your BOLI portfolio and a firm that is dedicated to Kentucky community banks, talk to Lou Moore & Lon Haines at Banc Consulting Partners.

Lon P. Haines

MANAGING PRINCIPAL 267.773.7617 PHONE 856.577.7305 MOBILE lphaines@yourbankpartner.com

www.bancconsultingpartners.com


CHAIRMAN’S CORNER

First Annual Chairman’s Cup Clay Shoot Hits the Mark

K

entucky has a long history and reputation for fine shooters. When running for office early in his political career, Henry Clay was asked if he was a straight shooter. The crowd assumed that only a true marksman could represent the Commonwealth in a proper manner. Clay quickly took the opportunity to refer to his propensity for telling the truth without political rhetoric, and became known as a straight shooter.

traveling the world to represent the American shooting sports. He then gave us a brief safety talk as that is always important for a fun day.

After the shooting, we enjoyed a reception complete with drinks and dessert, a raffle with On July 10th sixty seven bankers met at Elk Creek for the many door prizes for all and the inaugural Chairman’s Cup. We shot a round of sporting long-awaited announcement of clays at one of the finest shooting clubs in the country! the winning team and individual shooters. There were very impressive Elk Creek has hosted many events for both scores including three shooters who scored corporate and charity outings, and even the Sporting 98 out of 100! Now that is some straight U.S. Open. (That’s the U.S. sporting clays clays is shooting. open for you golfers who are wondering) Sporting clays is a bit like golf with a shot a bit like Congratulations to the top male shooter, Mr. gun. Shooters participate in foursomes and golf with Spike Harmon, and the top female shooter, travel from station to station (15 in all) to a shot gun. Ms. Hollie Wallace! shoot clay targets that are thrown in different presentations. Scores are tallied with the goal Best of all, the KBA staff designed a trophy to break as many targets as possible out of 100. It is comto be housed at the KBA offices. (See page 10)The custom petitive, a test of eye-hand coordination and lots of fun! designed trophy has four glass sporting clay targets flying Not to mention the camaraderie, occasional heckling and in formation with the last one broken…representing the bantering from those in your foursome. targets we hit! The winning team gets their name on the The KBA staff did a fantastic job organizing the event. trophy and unlimited bragging rights for one full year. I (Thank you especially to Yvonne, Angie, Debra, Selina hope this is the start of an annual event that will help fund and Josh) We enjoyed a great bar-b-que lunch in a well our PAC. I know Heritage Bank will be back participatdecorated pavilion. We had an extra hour for visiting while ing…of course we will also be bragging about our score waiting for the rain to blow through. Then we hopped in for the next 12 months! our carts and went out on the course to shoot. Some were old pros…some had never shot before…most had not shot sporting clays before…but all had a great time! We were joined by George Quigley, Jr. a 13-time All American, and Gold Medalist from both the Olympics and the World Games. George shared with us his experiences

H. Lytle Thomas KBA Chairman

Chairman’s Cup Clay Shoot Photo Gallery See pages 10/11 August 2015 | 5


STRAIGHT TALK

Unfortunately It’s Alive; or, The Monster that is Dodd-Frankenstein

M

ary Shelley, author of the gothic novel Frankenstein, called Dr. Victor Frankenstein’s lab, where the mad scientist created his monster, a “workshop of filthy creation.” In July of 2010 a pair of mad scientists in Congress took to their “workshop of reactionary creation” to enact the Dodd-Frank Act, better described as Dodd-Frankenstein. There were many of us who predicted the monster that would result. There were many of us who knew DoddFrankenstein would NOT revitalize the economy. Even Senator Christopher Dodd, who led the effort to get the bill passed in the Senate, said in 2010 at the signing of his creation: “No one will know until this is actually in place how it works.” More prophetic words have not been spoken. DoddFrank’s creation, an 848-page monster, claimed it would promote “financial stability” and end “too big to fail” dynamics, despite the fact its author, even at the birth of his namesake bill, did not know how it would work, and by extension, if it would work. Since Dodd-Frankenstein came into existence on July 21, 2010, our financial industry is less stable, less secure and more at the mercy of a law that was created out of an irrational fear; fear begets monsters. The financial giants have gotten bigger and, as a result, traditional banks are fewer in number. Our community banks are choking on the 400 rules and regulations built into Dodd-Frankenstein. This is the financial environment we are supposed to do banking in. Because of Dodd-Frankenstein, small banks are finding it extremely hard to serve their communities. We spoke to Congressman Andy Barr about this recently (see July issue of Kentucky Banker), and he told us about an ABA survey that reported 80 percent of those polled believed that regulations associated with Dodd-Frank are compromising credit availability. Because of Dodd-Frank’s mortgage rules many community banks are getting out of the home loan business altogether or substantially cutting

back —often in rural areas that most need credit. There are 1500 less community banks now compared to when Dodd-Frankenstein was enacted. This loss of community banks will damage the fiber of our communities and our economy. Community banks make the majority of small business loans, but the regulations are so complex and restrictive that it inhibits this vital part of our economy. Our economy cannot move forward until this is rectified and banks are allowed to do what they know — provide financial services to their communities. Dodd-Frankenstein was written to correct a wrong that Congress erroneously attributed to all banks —the 2008 financial crisis. This monster law was created to exact misplaced revenge from those in Congress with a pitchfork to grind. Certain members of Congress in 2008 showed a remarkable shortage of self-awareness when the crisis came to a head. Truth be told, government policies, written and proliferated by Congressional leaders at the time of the crisis, created the financial fall. The primary policy that led to the economic meltdown in 2008 was affordable-housing mandates that date back to 1977. The mandates led to a marketplace where people were purchasing houses they could not afford. With interest rates held at unprecedented lows by the Federal Reserve, it wasn’t a matter of if the housing bubble burst, it was a matter of when. Congressional leadership failed to prevent the crisis it created. Here are some of the most significant problems created by Dodd-Frankenstein that are still apparent:

Regulatory Red Tape Regulators have issued nearly 14,000 Federal Register pages of proposed or final rules affecting banks, with many more still to come. While only half of Dodd-Frank’s costly regulations have even been implemented, consumers, community banks and the economy have already been saddled with the consequences.

continued on next page

August 2015 | 6


STRAIGHT TALK One Size Does Not Fit All The Volcker Rule, instead of only applying to the largest banks, was written to apply to everyone, including community banks that pose no systemic risk. Five different regulatory agencies are involved in the Volcker Rule, creating further chaos and uncertainty. When everyone is in charge, no one is in charge. The buck stops nowhere.

Housing Recovery On Hold Regulations coming out of Washington have made it more difficult for people to qualify for a mortgage and more banks unable to make loans that the experts (the bankers) know are good loans. Common sense changes, including allowing loans banks keep in their portfolios to be considered QM loans, would increase access to mortgage credit.

Hidden Costs A new regulation or a bill in Congress may not come with a price tag, but banks have to hire new staff and outside

contractors to help it navigate a world with so many new regulatory landmines, and those costs function as a hidden federal tax on bank customers.

Two Popular Portrayals There are two popular portrayals of the Frankenstein monster. One is inspired by the 1931 Universal film version of the monster grunting inaudibly with bolts in his neck. This iteration is ignorant, dispossessed and clunky. (Sound familiar?) But this is not the character Mary Shelley created in her book. Her creature was self-aware, curious, and was able to educate himself. He read Paradise Lost and learned language with surprising speed. When we consider what must happen to reform the regulations that bolt your banks to the operating table, let’s work toward a new creation that will be more like Mary Shelley’s progeny who was intended to be a Modern Prometheus, and not the monster movie dolt that Dodd-Frankenstein so aptly resembles.

Let me know what you think: bcassady@kybanks.com

BankPac Check Presentation ABA Summer Leadership Meeting Baltimore, Maryland July 13, 2015 Pictured from left to right: Mr. W. Wes Hoskins Chairman, BankPac President & CEO First Community Bank Corpus Christi, TX Luther Deaton Jr. Chairman, CEO & President Central Bank & Trust Co. Lexington, KY Rob Nichols Incoming ABA President & CEO Washington, DC John A. Ikard Chairman, ABA President, FirstBank Holding Co. Lakewood, CO Ballard W. Cassady Jr. President & CEO Kentucky Bankers Association Louisville, KY

Ballard Cassady KBA President & CEO


MY TWO CENTS, PLUS SOME

Kentucky has a Long, Rich History in Hemp Production of All Types

K

entucky has been growing Hemp (both industrial and, let’s face it, recreational) for hundreds of years. For purposes of this article we will only focus on industrial grade Hemp, which does not have the chemical strength to cause a physical reaction and which is a wonderfully versatile crop. As a matter of fact, Kentucky has one of the longest traditions of industrial Hemp production, going back 400 years. The Hemp industries, and the confusion between the two types, continue to be a hot topic of discussion both locally and nationally. While only a few states have legalized recreational Marijuana, industrial Hemp is really the important story. Kentucky is poised to be a principal player in Hemp production and industry. Its importance lies in the fact that Kentucky’s farmers have lost 40% of their income in the last 10 years because of lost value in traditional crops and other reasons. Kentucky banks need to understand the legal requirements imposed on the industry, as well as the possible objections from examiners, in order to take full advantage of the possible opportunities. First, it is important to note and understand the distinction — the Federal Government does not regulate Hemp, it prohibits it and until recently made no distinction between industrial and recreational types. In a preemptive move towards re-establishing Hemp as a premiere industrial crop, Kentucky passed Senate Bill 50 in 2013 exempting industrial Hemp from the state controlled substances act, but also mandated all federal rules and regulations must be followed. At the same time, Kentucky started working with Congress to seek recognition of industrial Hemp as a legal crop. As a result, in 2014, Section 7606 of the Agricultural Act was passed to allow state departments of agriculture, in states where industrial Hemp is legal, to administer industrial HEMP pilot programs for the purposes of research and development. Kentucky’s program was in place before the ink was dry.

lending and deposit taking. You need to know what is legally required and you might need to educate your examiner. First, producers who participate in Kentucky’s Hemp Agriculture Products Programs must go through a legal certification process for a specific quantity of Hemp production. The certification process requires the following: - Application; - Criminal background check; - History of seeds used; - Specific plan on where/how growing will occur and GPS coordinates of the land to be used; - Approval of the above; - Memo of Understanding with the Kentucky Department of Agriculture; - Notification to local law enforcement; AND - Advanced Notice of legal harvest and transport throughout the production cycle.

Many of the items required for certification were established with the support of law enforcement to ensure that they could distinguish between legal vs illegal crops and transport. A bank can request access to all of this information and much of it is publicly available. Of additional interest to banks is the fact that general crop insurance does not necessarily cover Hemp production. Make sure that any crops that you take as collateral are fully insured by appropriate specialty lines.

Could Kentucky be the Silicon Valley of Hemp?

Once the laws passed, Kentucky’s principal players jumped at the chance to start production. While other states have passed similar laws to those in Kentucky, the startup has been much slower. Kentucky’s industrial Hemp program is small but increasing every year. In 2014, 8 Hemp Pilot Projects were approved. In 2015, 100 Hemp Pilot Projects were approved out of 320 applications. Venture capitalists from around the world are coming to Kentucky to learn about the crop and to ensure they are on the leading edge. Could Kentucky be “the Silicon Valley of Hemp?” Banks need to be prepared to take advantage of this opportunity as well. That means fully understanding the legal issues that regulate this industry. Banks will be called upon for August 2015 | 8

The KBA has met with the Department of Financial Institutions and others to discuss how we can educate all involved parties (regulators, bankers, producers) on this industry and its impact on financial services. We are working to make this opportunity as readily available to you as possible.

You are probably wondering just how much income Hemp can bring to our Commonwealth. Here are some facts: Over $630 million of Hemp products are currently imported into the United States. That number could significantly increase if the Hemp is grown domestically and the export possibilities are huge. The profitability of Hemp ranges from $600 to $800 per acre, depending upon the grade. This is a significantly profitable crop. We will be posting more information regarding Hemp production.

DEBRA STAMPER KBA EVP & General Counsel


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FIRST ANNUAL CHAIRMAN’S CUP CLAY SHOOT Top row: Pictured in blue shirt/hat KBA Chairman Lytle Thomas and Chairman’s Cup winners. Photos by Josh Fischer.

First Place Team Division - Heritage Bank, Inc. of Erlanger

First Place Women’s Division

First Place Men’s Division

Lee Scheben, Terry West, Ralph Bruewer (Skip Seltman not pictured)

Hollie Wallace, Wallace & Boggs, PLLC

Spike Harmon, Bank of Edmonson County

August 2015 | 10

Bottom row: 2015 Chairman’s Cup Clay Shoot Door Prizes. Thousands of dollars of door prizes were awarded.


FIRST ANNUAL CHAIRMAN’S CUP CLAY SHOOT This page: 2015 Chairman’s Cup Clay Shoot Teams


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KENTUCKY BANKER

It’s time to end credit unions’ tax break by James M. Pishue, President & CEO, Washington Bankers Association

T

hese days you can hardly open the paper or listen to the radio without being bombarded with advertising for a credit union soliciting new “members.”

it would add more than $30 million annually to the state treasury.

But in most cases, “members” is simply a misleading term for “customers.” That’s because the largest credit unions have thrown open their doors to any resident of the state of Washington.

That $30 million could pay for about 400 more teachers to improve education across the state. Or it could be used to enhance public safety or provide services to those who need them.

It’s an important distinction. One of the key factors in the growth of local credits unions is competitive advantage that can no longer be justified by their organizational structure. More importantly, this advantage takes money out of the pockets of everyone else in our state. Most people are unaware that credit unions — unlike banks — don’t pay federal income tax or state business taxes. This exemption may have been appropriate during their infancy before World War I, when credit unions served distinct and narrowly defined groups of members with some common bond. Back then, credit union members were individuals of modest means with limited access to traditional banking services. Today, banks serve a larger percentage of modest income consumers than credit unions. Many credit unions have now evolved into mirror images of banks and thrifts, open to any and every one. They compete directly for individual and small business customers. They advertise aggressively and their websites trumpet “banking” services.

This big credit union tax loophole means that other Washington taxpayers are paying more to subsidize both local and national organizations doing billions of dollars of business in our state. The same holds true at the federal level, where taxing credit unions on the same scale as their bank counterparts would add more than $2 billion annually for government services.

Credit unions portray themselves as banks all the way up until it’s time to make out that tax check to the government.

In fact, these credit unions portray themselves as banks all the way up until it’s time to make out that tax check to the government. There are 55 credit unions located in our state with $50 million or more in assets. Major credit unions headquartered elsewhere operate here, too. If these institutions were to pay business taxes at the same rate that banks do,

There’s precedent for eliminating credit unions’ tax-exempt status. In 1951, Congress eliminated tax-exemptions for savings and loan associations and mutual savings banks, whose cooperative ownership structure is very similar to that of credit unions. The rationale given then was that these entities had outgrown their tax-exempt status because they were “actively in competition” with tax-paying financial institutions. It’s exactly the situation with credit unions today.

The Washington Legislature is under a Supreme Court order to fully fund basic education. That means seriously tackling the budget challenges facing our state. It’s time for lawmakers to start asking why big credit unions not only don’t pay their fair share — but also why they pay no share at all. August 2015 | 13


KBA VENDOR SOLUTIONS

findCRA Simplifies Community Reinvestment KBA is pleased to announce that findCRA.com is a KBA Vendor Solution! findCRA is an innovative service that connects banks with community needs. Through their unique online platform, findCRA provides meaningful, easy connections with CRA-focused projects listed by community partners. As a bank partner, KBA members can find the CRA-qualifying opportunities when you need them, in the assessment areas that matter to your bank. With findCRA, community connection has never been easier! Because their process is simple, findCRA eliminates much of the time, energy and resources typically expended researching, organizing and sharing basic information, before and after projects are completed. In the short-run, KBA members can use your bank’s time and resources more effectively, while findCRA finds the qualified CRA opportunities for lending, investment and service. In the long-run, KBA members have a centralized place to identify the opportunities your bank needs to meet your benchmarks on the road to an Outstanding CRA examination. In addition, KBA’s HOPE of Kentucky program is an Affiliate with findCRA.com. Information is included on the findCRA. com website where you can learn more about earning credit with HOPE of Kentucky. Over the past year, findCRA has focused on serving the Louisville and Southern Indiana market, but has now expanded its services to banks throughout the entire state of Kentucky and all of Southern Indiana.

KBA members who use findCRA will have access to all of these great benefits: Detailed community project listings outlining needs and impact; CRA Analysis for each project listing; Notification of projects in your assessment areas; Search projects by CRA category or geography; Historical reports of online connections; Request a specific opportunity or partner in targeted areas through the Targeted Connection service; Invitations to exclusive networking events; and, Educational content and webinars. Check out these benefits offered and register at www. findCRA.com. Please contact Selina Parrish at the KBA at (502) 736-1282 or sparrish@kybanks.com if you have questions and need additional information on this KBA Vendor Solution.

The Lighter INTERESTing Bank Puns I used to be a banker, but I lost interest. Side of Banking Two banks with different rates have a conflict of interest. Interest has such accrual way of accumulating.

August 2015 | 14


KENTUCKY BANKER

Kentucky Banker Participates in SBA Roundtable on Overtime Proposal Cristeena G. Naser of the ABA Banking Journal reported that Karen Glenn (pictured at left), president and CEO of First United Bank and Trust Company, Madisonville, Kentucky, and member of the ABA’s Community Bankers Council, participated in a roundtable hosted by the Small Business Administration on the Department of Labor’s overtime proposal. The overtime proposal would more than double the salary basis test, the level below which all employees must be paid overtime beyond 40 hours per week, regardless of their duties, raising it to $50,544 per year. Glenn said that the variance in the cost of living from state to state was not taken into consideration in DOL’s calculation of the new salary test. She also cited the number and percentage of employees in her bank that would no longer be exempt, the potential additional overtime costs and the impact of the change to non-exempt status on employee morale, particularly with respect to branch managers. ABA opposes these changes and is advocating on behalf of our members in a number of arenas. ABA is part of the Partnership to Protect Workplace Opportunity (PPWO), a broad coalition of trade associations opposing the proposal. The PPWO, as well as ABA and other bank trade associations, have filed letters seek-

ing an extension of the comment period, now set for September 4. ABA will participate in a joint trades letter responding to the proposal and will file its own letter focused on the impact on community banks. ABA needs feedback from you to effectively inform Department of Labor of the impact on community banks. We need you to share your stories of how the proposal would affect your bank for inclusion on an anonymous basis in ABA’s own letter. You may want to consider presenting the following aspects of your stories: • Number of currently exempt employees who do not earn $50,544 annually and their percentage of total workforce; • Potential costs of overtime; • How long such employees have been exempt; • Morale problems as a result of losing exempt status; • Whether the other employee benefits (health care, etc.) you provide are higher than in your general area, i.e., the total compensation package; and • Loss of flexibility for both the bank and its newly nonexempt employees. Please send stories to: cnaser@aba.com Original story (July 21, 2015) — http://bankingjournal.aba.com/2015/07/bankerparticipates-in-sba-roundtable-on-dol-overtime-proposal/

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KENTUCKY BANKER

What do you need to know about the FFIEC Cybersecurity Assessment Tool? by Jon Waldman, Partner, Secure Banking Solutions, LLC

A

s promised in their 2014 Cybersecurity Observations Another significant question that needs to be addressed is publication, the FFIEC has released new guidance how this new assessment affects what institutions are curin the form of a Cybersecurity Assessment Tool. As rently doing regarding a documented Information Security one would expect, it has a heavy focus on CEO and Board Program. Please be sure to understand – this new Cyberselevel involvement, as well as tying controls to other FFIEC curity Assessment Tool is not a replacement for any current and NIST resources in order to assemble a set of expecta- risk management process; it’s an addition to current Information Security Program processes that ensures tions for financial institutions based on their financial institutions have adequate controls size and complexity. It’s essentially giving institutions in place to mitigate the risk of cyber-specific However, this new assessment tool not only threats. This doesn’t replace anything from a examination provides financial institutions a method to or traditional ISP, including an asprocedures that standard evaluate the maturity of their Information Seset-based IT Risk Assessment. It’s a different they can use to vantage point that should allow Senior Mancurity Program to address cyber threats, but point to exactly agement and the Board of Directors to better it also gives examiners a method to create a where they are in understand the institution’s maturity when it risk-based cyber examination process. the realm of to preparing for and mitigating risk If you think about the old FFIEC handbooks, cybersecurity, as comes around the increasing cybersecurity attacks which don’t really delineate between instituwell as exactly that are affecting networks and organizations tions of different size and complexities... that’s where institutions on a much more regular basis. exactly what the FFIEC appears to be doing need to be here on the cybersecurity side of the informaregarding the So, what are the big takeaways for those that tion security world. Interestingly enough, this implementation need to understand this new tool at your own new tool is also very prescriptive in that inherfinancial institutions? First, the assessment of controls. ent risk and maturity expectations are outlined tool identifies and creates a baseline of (inin specific detail, which is another (welcome) herent) cybersecurity risk for the institution. change from traditional guidance. It’s essenIt then compares the current maturity level tially giving institutions examination procedures that they of the intuition against risk-based expectations and identifies can use to point to exactly where they are in the realm of gaps in the cybersecurity controls needed to meet the maturicybersecurity, as well as exactly where institutions need to ty expectations. If the institution does not meet the identified be regarding the implementation of controls. cybersecurity maturity levels, then the assessment suggests improvements to existing risk management and information For those who have completed the FDIC IT Officers ques- security program components. tionnaire in the past, this tool resembles that process very closely with two significant differences: the FDIC Officer’s The FDIC has also released this FFIEC Cybersecurity AsQuestionnaire has a signature line for accountability but sessment Tool as FIL-28-2015 and states that the use of this does not have a risk-based scoping process to vary expecta- new tool is “voluntary;” however, we have seen many times tions on institutions based on size and complexity. in the past that voluntary processes or items-not-mandated continued on next page

CYBERSECURITY SEMINAR Come one, come all. . . security officers, technology staff, CEOs, senior managers, operations personnel and anyone with responsibilities or interest in bank security and technology . . . Join us for a look into Cybersecurity. Register Today! Two Locations: BOWLING GREEN October 22, 2015 @ Hilton Garden Inn

LEXINGTON October 23, 2015 @ Marriott Griffin Gate

Online registration is available at: www.kybanks.com (Education Solutions/Seminars) August 2015 | 16


KENTUCKY BANKER continued from previous page

are still used in examination processes. Technically, all of the FFIEC IT Booklets are voluntary resources. It’s important that each financial institutions quickly get familiar with this new Cybersecurity Awareness Tool and understand where their institution stands in terms of inherent risk and cybersecurity maturity. Once you understand your inherent risk and maturity levels, your next step is to develop a list of next-steps to improve gaps in the cybersecurity maturity model identified by the FFIEC. Examiners will likely not expect full compliance with these identified cybersecurity controls tomorrow, but there will certainly be an expectation that institutions start leveraging this resource and making steps toward the identified goals. SBS is working to automate this manual assessment tool into a freely available resource that financial institutions can use to quickly and easily perform their own assessment.

If you’re interested in pre-registering for this free web-based application, please visit our website here: https://www.protectmybank.com/register/ For more information about the FFIEC Cybersecurity Assessment Tool, you can find links to the resources and a copy of the tool at www.protectmybank.com. SBS will continue to provide additional articles and updates on educational opportunities on our website, so stay tuned.

Community-Bank-Specific Programs The SBS Institute has partnered with the KBA to offer Community Bank specific certification programs. These certifications are being offered to you by the KBA through the SBS Institute to further your career, impress your examiners, and protect your organization against today’s security threats. Certifications are being offered online in a structured 14-hour course where you will have access for 10 weeks.

For more information, please contact: Paula Cross at pcross@kybanks.com

75 U.S.

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KBA EMERGING LEADERS

Regulator Forum sparks discussion on industry hot-button topics by Jonathon F. Lewis, Commercial Bank of Grayson

K

entucky Bankers from across the state gathered for one of two Regulator Forum sessions organized by the KBA in June. Individuals representing the KDFI, FDIC, Federal Reserve, OCC, and CFPB created a panel that covered hot topics ranging from the ever changing role of a director to cybersecurity. As a member of the 2015-2016 KBA Emerging Leaders Program, I was honored to attend the Lexington session. This program in particular opened my eyes to the issues facing community banks and the general economy of Kentucky and our nation. Here are a few of the key takeaway items which struck me as both important and interesting.

EXPORTS MATTER Morgan Pierstoff with the Kentucky Cabinet for Economic Development spoke on the financial industry’s vital role in job creation and promoting the state’s growth in exporting. Kentucky continues to break exporting records, sharing products and services with the world. This has become a very successful focus and growth potential for state economic development, contributing 11.3 billion to the states GDP, and 1 billion in state and local taxes. Records indicate that less than 5 percent of Kentucky businesses are exporting, providing ample opportunity for export growth. The financial industry can get involved by initiating conversations with small business owners on those opportunities and resources available to them. The Cabinet introduced to attendees the Kentucky Small Business Credit Initiative, a tool for lenders for loans just outside underwriting standards. KSBCI can provide up to 20 percent of collateral support on projects, becoming a partner to help make those small loans acceptable. Contact Morgan to discuss what role they can play in partnering with your institution at (502) 782-1976.

CHANGING ROLE OF THE DIRECTOR The role of the director continues to change as the expectations expand and their accountability grows. The importance of their ability to have a general knowledge of bank operations sufficient to provide effective oversight is necessary. Many directors fear that with the growing Cybersecurity concerns that they are expected to be seen as experts; however, this is not really the case. Directors need a general

knowledge that will enable them to effectively oversee bank strategy and direction. This will enable them to make decisions in managing and mitigating risks in their respective institutions. An active rather than passive board member that asks the right questions and challenges management is an asset to an institution.

CONCERNS ABOUT LOAN PORTFOLIOS Kentucky’s economic outlook continues to look favorable; nearly 95 percent of jobs have been recovered from the recession. Community banks generally have remained profitable, with an ever growing loan portfolio. However, something which is a concern for the future is that bank portfolios still maintain a high concentration of municipal holdings. As evidenced from large cities in the nation that have fallen into financial struggles, a review of the ability to pay debt by municipals should be considered. Due to ever growing liabilities and deficits in pension funds, some municipals may find themselves in difficult positions without a change in direction in the near future.

RISKS COMMUNITY BANKS FACE NOW Tim Bosch, V.P. of Federal Reserve of St. Louis, informed the group on the background of many of the mergers being seen. Several can be found to be initiated due to generational turnover, not necessarily that of regulatory environment as the driving factor. The difficulty to attract competent management and employees are issues that affect many rural financial institutions. As well many banks are failing to have an effective management succession program in place. Ignoring these concerns only heightens the risk of exposure for the institution.

THIRD PARTY VENDOR MANAGEMENT Institutions continue to grow their outsourcing of a variety of services (IT, audit, legal, tax, products and services, etc.), but must maintain effective risk management regardless whether the bank performs an activity internally or through a third party. Regulators see smaller institutions with relationships with over 100 vendors; this creates a large responsibility for the management and oversight that is required. Institutions should adopt a risk management process commensucontinued on next page

August 2015 | 18


KBA EMERGING LEADERS rate with the level of risk and complexity of its third-party relationships. Those vendors that involve critical activities or sensitive information should be comprehensive in both management and oversight.

CYBERSECURITY Cash is no longer a bank’s most valuable asset, it is the information banks possess. While institutions have diligently worked to protect funds secured in their facilities with multiple barriers to intrusion, a much more difficult task is dealing with the cyber security needs. An article presented by the OCC that was published in the Wall Street Journal highlighted several items that companies are failing to do adequately: - Patch Management; - Securing Online Doors; - Encrypting Data; - Password Management; and - Vendor Management. All of these can become vulnerabilities that can create a cyber-security event for an institution. Regulators emphasized

the importance of practicing responses to incidents, ensuring awareness and accountability for staff, and educating customers. The importance of the investment in mitigating controls, education, and preparation could not be stressed more. These were just some of the important takeaways from the 2015 Regulators Forum. I know that when I go back to my bank, I go back with more knowledge of the industry and the economy of Kentucky. I am very thankful to have the opportunity to attend programs like the Regulators Forum through the Emerging Leaders program. More knowledge of the industry and the issues facing it will assist me with my career and the direction of my bank.

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BANKERS ON THE MOVE Amber Ousley

Chris Conkright

Central Bank has announced the promotion of Amber Ousley to Credit Analyst Officer. Amber began her career at Central Bank as a teller in 2006. She brings experience as a personal banker, loan processor and credit analyst to her new role. Amber is a graduate of Indiana Wesleyan University where she earned her BA in accounting; she also holds a BA in graphic design.

Central Bank has announced the promotion of Chris Conkright to Credit Analyst Officer. Chris began his career at Central Bank as a credit analyst in 2014. He brings more than four years of experience as a credit analyst to his new role as credit analyst officer. A graduate of Centre College, he holds a BS in financial economics.

Darren Spainhoward

Joan Strafer

Your Community Bank has named Darren Spainhoward as Regional President. Spainhoward will be responsible for the development of the Your Community Bank brand in the Evansville market, as well as community outreach and hiring of additional personnel. Previously, Spainhoward served as Senior Vice President of Commercial Lending at Old National Bank. He has 25 years of banking experience.

Central Bank has announced that Joan Strafer has joined Central Bank as Vice President, Commercial Lending. Mrs. Strafer brings 22 years of banking experience to her new role. A graduate of the University of Louisville, Joan will work from the Hurstbourne location as a commercial lending officer. Active in her community, Strafer is a member of the Junior League and The Fillies.

Michelle Young

Shane Anderson

Traditional Bank is excited to welcome Michelle Young to the position of Banking Center Manager at our Lansdowne location. Young has 20 years banking experience. She is a Danville, Kentucky native and has lived in Lexington since 1995. Young is currently on the board of The Chamber Music Festival in Lexington.

Central Bank has announced the promotion of Shane Anderson to Assistant Vice President, Commercial Lending. Shane began his career at Central Bank as a teller in 2003. He has worked as a personal banker, training specialist, credit analyst, credit officer and commercial lending officer. He is a graduate of the University of the Cumberlands and also holds an MBA from the UK.

Will Sanders

Jeanne Willard

Planters Bank welcomes Will Sanders to its commercial banking division as assistant vice president. A native Clarksvillian, Sanders spent the last few years as executive director and country manager for Hancock Prospecting Mongolia, LLC. Prior to that, he worked as financial advisor at Bank of America Merrill Lynch and financial services officer at Farm Credit Services of Mid America.

Jeanne Willard was recently promoted to vice president of retail banking at Citizens Union Bank in Shelbyville, Kentucky.

Trena Floyd

Cyndi Caldwell

Trena Floyd has been promoted to Vice President & Business Services Officer at Your Community Bank in Elizabethtown. She will cover Jefferson, Hardin, Hart, Meade, and Nelson Counties, and will oversee and manage a commercial business loan portfolio by advising business owners on their management and operations. She has over 20 years of experience in the industry.

Central Bank has announced that Cyndi Caldwell has joined Central Bank of Jefferson County as Assistant Vice President, Commercial Real Estate. Cyndi joins Central Bank with 24 years of banking experience, 11 of which were in commercial real estate. A native of Louisville, Cyndi attended Western Kentucky University and Webster University.

Jeremy Gray

Donnitta Pyle

United Bank is pleased to announce that Jeremy Gray has been promoted to Vice President and Senior Lender for Woodford County. Jeremy is a graduate of Western Kentucky University and has been with the bank since September 2013. He has been a lender since 2001. He resides in Lexington with his wife and two daughters.

FNB Bank recently promoted Donnitta Pyle to Vice President. Pyle, from Wingo, KY, has extensive experience in the banking industry. She has served the Mayfield-Graves County community for over 30 years in a variety of roles. Pyle is a graduate of the Graduate School of Banking at Louisiana State University and has also attended the General School of Banking in Louisville, Kentucky.

Want to announce a promotion? Email photos & announcements to Angie White awhite@kybanks.com August 2015 | 20


BANKERS ON THE MOVE

Kentucky Thrift Foundation and Central Kentucky League of Savings Name Officers At the 21st Annual Meeting of the Kentucky Thrift Foundation (KTF) held on June 25, 2015 at the Marriott Resort Griffin Gate in Lexington, officers were named for the 20152016 fiscal year. Mr. Glenn Meyers, CEO, Kentucky Federal Savings & Loan Association, Covington currently serves as President of the KTF. Mr. Ryan Steger, Regional President, Town Square Bank, Mt. Sterling, serves as Vice President of the KTF. Both currently serve on the KBA Board of Directors representing thrift institutions. Also at the June 25 joint meeting of the Kentucky Thrift Foundation and Central Kentucky League of Savings Institutions, Mr. Steger was elected to serve as President of the Central Kentucky League of Savings Institutions for 2015-2016. Mr. David Shadburne, President/CEO, Winchester Federal Bank, Winchester was elected to serve as the Vice President of the Central Kentucky League of Savings Institutions.

KTF Officers: left to right – Mr. Glenn Meyers and Mr. Ryan Steger

Following the KTF annual meeting, a joint dinner was held with the Central Kentucky League of Savings Institutions where Past Presidents of the Kentucky League of Savings Institutions are invited to gather for the joint dinner and meeting of the Central Kentucky League of Savings Institutions. Those attending the dinner were: Mr. Bill Woodward, Past President of the Kentucky League in 1969, Mr. Arthur Raderer, Past President of the Kentucky League in 1973, and Mr. Edward Whitehead, Past President of the Kentucky League in 1980. The Kentucky League of Savings Institutions was founded in 1896 and merged with the Kentucky Bankers Association in 1995. There are currently nine thrifts participating in the Kentucky Thrift Foundation.

Past Presidents – left to right - Mr. Bill Woodward, 1969 Past President; Mr. Arthur Raderer, 1973 Past President; and Mr. Edward Whitehead, 1980 Past President

Chrisco Named CFO of the Year Paul Chrisco, Executive Vice President and CFO of Community Bank Shares of Indiana, Inc., the holding company for Your Community Bank and The Scott County State Bank, has been named CFO of the year in the small public company category by Louisville Business First. Each year Business First hosts an awards ceremony to honor the region’s most successful chief financial officers. This year’s honorees have helped to grow their company’s in a variety of ways — acquisitions, tax planning and debt refinancing. Chrisco received the award at the CFO of the Year awards luncheon today.

Chrisco has 22 years of experience in banking, and has spent 14 years as CFO of Community Bank Shares of Indiana, Inc. He began his career with American National Bank in Indiana before moving to Community Bank Shares Inc. in 1997. “It is an honor to be selected,” Chrisco said. “To be recognized for this award is really a testament to all of the great people at Your Community Bank. All of our employees strive to provide exceptional service to our customers and we pride ourselves on being a good corporate citizen by giving back to the communities in which we operate.”


BANK HAPPENINGS

Community Bank Shares of Indiana, Inc. Announces Corporate Name Change Community Bank Shares of Indiana, Inc., the holding company for Your Community Bank and The Scott County State Bank, announced that it has officially changed the name of the company to Your Community Bankshares, Inc. In conjunction with the corporate name change, the company will change the ticker symbol listed on NASDAQ from “CBIN” to “YCB” effective July 1, 2015. “We are very pleased to align our corporate name and stock symbol to better represent the company’s growing footprint across the region,” James D. Rickard, President and Chief Executive Officer of Your Community Bankshares, Inc., said. “The completion of the company’s acquisition of First

Financial Service Corporation of Elizabethtown earlier this year positioned us for additional growth in new markets. As Your Community Bankshares, Inc., we are well-positioned to continue strengthening awareness among investors and customers in the growing number of communities we serve.” Your Community Bankshares, Inc. operates more than 35 financial centers in Clark, Floyd and Scott counties in Indiana, and Bullitt, Fayette, Hardin, Hart, Jefferson, Meade, and Nelson counties in Kentucky.

CFSB Communi-TEA Humane Society Fundraiser held at Benton Banking Center Community Financial Services Bank (Benton, Kentucky) Team Members and their children held a Communi-TEA & Lemonade Fundraiser for the Marshall County Humane Society on Friday, July 10th. Along with the drinks, the

Kaydence Kindle serves Tea to CFSB Team Member Dallas Jo Young

Humane Society also had animals on hand for adoption as well as micro-chipping available. The Communi-TEA raised more than $800 for the Humane Society.

Kinsley Cloninger and Anney Kelly wait for a customer at the Communi-TEA Humane Society Fundraiser

Bank of Cadiz Groundbreaking in Murray, KY

August 2015 | 22


BANK HAPPENINGS

Community Financial Services Bank Celebrates 125th Anniversary

C

ommunity Financial Services Bank (CFSB) has reached an important milestone in serving its local community. This past May marks the community bank’s 125th year of helping individual and small business customers with their financial needs. “It’s been an honor to support our community all these years, and to see it grow and thrive” said Betsy Flynn, President/ CEO/Chairman of CFSB. “We look forward to continuing our tradition of working hard so that local consumers can experience the community bank difference for years to come.”

History of CFSB Until 1890, commerce had always been slowed in Marshall County, Kentucky because there was no bank. When construction of the Paducah, Tennessee and Alabama Railroad began in 1889, a number of county businessmen set in motion plans to incorporate a bank. In March of 1890, a bill was introduced in the General Assembly in Frankfort. This bill received final approval on April 16, 1890, thus the Community Financial Services Bank was born. The capital stock

of CFSB was initially $12,500.00. From this humble beginning, CFSB has not only grown financially to more than $700 million, but the bank itself has become an institution in Calloway, Marshall and McCracken counties. CFSB has also grown from one site on the Benton Court Square to three Marshall County locations as well as banking centers in Paducah and Murray. The organization is regional and poised for growth. Under the direction of President/CEO Betsy Flynn and Senior Management, CFSB, Inc. continue to have a vision for the future. “We anticipate the majority of future growth will be in electronic banking, where our valued customer can bank anywhere with no online or ATM fees,” said Flynn in a release. CFSB is a locally-owned and operated ESOP financial institution with headquarters in Benton, Kentucky. CFSB has locations throughout Calloway, Marshall and McCracken County in western Kentucky and employs more than 180 team members. Member FDIC.

CFSB Benton Branch

CFSB McCracken Branch

CFSB Calloway Branch

CFSB Calvert Branch August 2015 | 23


KENTUCKY BANKER

Compliance: Burden or Opportunity? by Scott Daugherty, President & General Counsel, Compliance Alliance

I

often hear bankers lamenting how compliance is a burden that is forcing banks to merge or sell. I find this to be a disturbing thought and one I wholeheartedly disagree with. As I travel across the country, talk of rising cost of complying with all the new regulations and having to add to the compliance staff is prevalent at conventions from coast to coast. I view this as a time of opportunity rather than a riddle that can’t be solved. Compliance Alliance works with banks in thirty-six states and as I visit these states I have talked to bankers at community banks that were founded in 1820, 1825, 1835 and many other banks that are in excess of 150 years old. Hearing the stories about the history of these institutions makes me think about the major events that these banks have survived and thrived through. They have been through: - The Battle at the Alamo - The Financial Panic of 1837 - The Mexican War - The Civil War - The Stock Market Crash & Panic of 1873 - The Financial Panic of 1893 - War World I - The Great Depression - War World II - Korean War - Vietnam War - The S & L Crisis As a banker, I find it amazing the number of banks across the country that have gone through these events and many other life altering and changing events. I know I would not want to be the banker whose bank went through all of those trying times and then I gave up because of Dodd-Frank. This made me contemplate our current challenges in banking and how banks can adapt and thrive in spite of the obstacles placed in front of them. I firmly believe that we have an opportunity to revamp and reevaluate how banks handle the compliance and regulatory functions. As bankers we are accustomed to adapting and overcoming challenges that we and our communities face.

bank. I know it isn’t a money maker but it is a money saver. Think of the fines and penalties you see banks being hit with every day. How many loans will your bank have to make to make up for a $250,000 fine or penalty that the bank suffers because it hasn’t invested in the compliance area? I cringe when I hear people refer to compliance as the people that say no all the time. If the answer is no all the time then I would argue the wrong question is being asked. Banks need to change their culture to include compliance in the planning and early stages of initiatives. Ask how can we get this done or what options do we have to work with this customer or how can we offer a better product? Compliance should be a part of the strategy of the bank as compliance touches on everything a bank does. This is the perfect time to focus on how to make your compliance area more efficient and effective. An important part of this is using resources that will give your compliance officer more time to work with staff to ensure the bank is staying in compliance with the regulations, guidance and rules that we face. Your compliance staff needs to monitor and evaluate the bank’s processes, train and coach staff on policies, procedures and best practices not to mention creating those policies, procedures and best practices. This is a time of opportunity and like with every other hurdle, bankers will take an obstacle and turn into an opportunity. Those banks that meet the challenge, adapt and innovate will continue to be efficient and profitable. Together, 24 State Bankers Associations and their Boards of Directors recognized this challenge and sought to offer a solution to assist banks in becoming more efficient and effective in their compliance and regulatory areas. You owe it to your bank and your compliance officer to see how you can become more efficient and effective in compliance.

We have dealt with changes to every area of our banks, the way we open accounts, process checks, make and collect loans, trust services, mobile banking, ATM’s and many, many more ways banks have evolved and thrived. Now it is compliance’s turn to adapt, thrive and become more efficient and effective.

Scott Daugherty is President & General Counsel of Compliance Alliance. Owned by 24 State Bankers Associations, Compliance Alliance monitors the needs of bankers to create, update and continually provide the most sought-after banking regulation resources in the industry.

But the compliance function has largely remained unchanged in how it operates within the bank. Compliance is such a vital area to the bank, it is as important as any other area of the

To learn how to put Compliance Alliance to work for your bank, call (888) 353-3933, visit compliancealliance.com, or email info@compliancealliance.com.

August 2015 | 24


KBA EDUCATION SOLUTIONS | EVENTS & SEMINARS CALENDAR Personal & Business Tax Return Analysis Seminar August 11 Bowling Green August 12 Lexington New Accounts - Pegasus Seminar August 17 Morehead August 18 Hazard August 19 Somerset August 20 Elizabethtown August 24 Paducah August 25 Bowling Green August 26 Lexington Internal Audit Seminar August 19 & 20 Elizabethtown Lending Compliance School August 24 - 28 Louisville

Certified Teller Seminars August 31 Paducah September 1 Marion September 2 Owensboro September 3 Bowling Green September 14 Grayson September 15 Prestonsburg September 16 Somerset September 21 Carrollton September 22 London September 23 Elizabethtown

PBS Live Seminars September 22 New Integrated Mortgage Disclosures - Somerset September 23 Mortgage Lending Start To Finish - Somerset September 24 Mastering HMDA Somerset September 29 ACH Processing Compliance - Bowling Green

Commercial Lending School September 21 – 25 Louisville PBS Live Seminars September 10 Flood Insurance Compliance Lexington

PBS Webinars August 11 IRS Reporting and Compliance Webinar Series Program 4: Types of Backup Withholding A, B, C & D and the IRS B & C Notices

Contact | kbaeducationsolutions@kybanks.com | 502-582-2453 tHIs Is AN ADvERtIsEMENt.

M&P’s John McGarvey to emcee 124th KBA Annual Convention The Westin Resort & Spa Hilton Head, South Carolina September 19-22, 2015

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Gearing up for 2015’s anticipated time of transition, bank managers are equipping themselves with the information they need to face the unique challenges and opportunities that lie before them. Making a successful transition requires the right tools, techniques, and processes. The Kentucky Bankers Association’s Interest Rate Risk and

October 7, 2015

Investment Strategies Seminar, presented by The Baker Group, is developed specifically for managers of financial institutions. Designed to meet the transition challenges of 2015, it is an

LOCATION

in-depth examination of current topics including:

Kentucky Bankers Association

• Bank Performance Trends and Industry Landscape • Asset/Liability Management: Finding Keys to High Performance • Game-Plans for a Shifting Rate Environment • Managing Investment Risk: Strategy and Tactics • Regulatory Expectations for Interest Rate Risk and Investments • Modeling Assumptions and Key Simulations for Interest Rate Risk • Security Selection Decisions: Cash Flow and Relative Value • Sector-Specific Risk Management: MBS Prepays and Municipal Bond Credit Analysis • Liquidity, Cash Flow, and the Bond Portfolio The Baker Group will again this year provide each bank in attendance a customized “bank sheet” reflecting numbers unique to their bank.

First Floor Training Room 600 West Main Street Louisville, KY

Speakers The Baker Group Jeffrey F. Caughron Lester F. Murray

Agenda 9:30 a.m. — 4:00 p.m. Breakfast Seminar Lunch

Who Should Attend Financial institutions’ CEOs, CFOs, investment officers, board members, and those who are directly or indirectly responsible fo r

financial

management

functions will benefit from this

Please contact Jamie Hampton at 502.582.2453 or jhampton@ kybanks.com. For a complete listing of KBA programs, or to register online, please visit www.kybanks.com. Dress is business casual.

seminar. CPE credits will be earned for your attendance.

Presented by

Kentucky Bankers Association | 600 West Main Street, Suite 400 | Louisville, KY 40202 | f 502.584.6390 | 502.582.2453


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