The Missouri Banker Volume 69, Number 10 • THE NEWSPAPER OF THE MISSOURI BANKERS ASSOCIATION • Thursday, October 17, 2013
Bankers visit legislators, regulators in Washington
In photo above, MBA member bankers and their guests visited with Missouri’s U.S. Sen. Roy Blunt during the 2013 Washington Visit earlier this month. In photo at left, MBA members visited with Congressman Emanuel Cleaver, who represents Missouri’s Fifth Congressional District in Western Missouri. He is one of four members of the Missouri delegation who serves on the House Committee on Financial Services. Read Max Cook’s report on the Washington Visit on Page 2, and see additional photos from the Visit on Page 8
11th Annual Directors Forum features Woody and Kohl
MBA’s Directors Forum begins its second decade with a double bill of top speakers. Thursday, October 31 in Columbia, J. Michael Woody, a well-known bank consultant, and Dr. David Kohl, a nationally respected
agricultural economist, will share their insight into the changing world of banking and provide tips and techniques to make these changes profitable to bankers. Kohl will show bankers and bank directors how an understanding of lead and lag
economic indicators can be used in setting a bank’s strategic decision making. His presentations are always well received and give attendees a much clearer understanding of the interconnectedness of global economies and their impact on the health of business, industry and banking. Dr. Kohl breaks down complex issues and explains the factors that impact interest rates, inflation and the growth of local and global economies. Mike Woody will then show how bankers and
bank directors can use this information to plan for their banks future course of operations. Among areas the forum will cover:
• The importance of director involvement • Maximizing shareholder value • Developing a bank’s strategic plan • Best practices for banks, directors and senior management Regulator roundtable Woody will also moder-
Visit our web site at http://www.mobankers.com
ate a regulator roundtable with top regulators from the FDIC, Division of Finance, OCC, and Federal Reserve Banks. Dodd-Frank Act MBA’s Denny Deischer will close out the day-long forum with a presentation on Directors’ Responsibilities under the Dodd-Frank Act. Still time to register To register for the Forum, call MBA at 573-636-8151. Discounts are available for two or more people from the same bank.
The Missouri Banker October 17, 2013
Message from the President
Washington Visit a success despite government ‘shutdown’ Max Cook President Missouri Bankers Association email@example.com The timing of MBA’s Washington visit couldn’t have been worse and couldn’t have been better. With 37 bankers and their guests making up the MBA The Missouri Banker
573-636-8151 Max Cook Publisher firstname.lastname@example.org William O. Ratliff Managing Editor email@example.com Sue Norfleet Editor firstname.lastname@example.org The Missouri Banker (USPS Number 000044, ISSN Number 0893-5637) is published 12 times a year (once a month) by the Missouri Bankers Association, 207 E. Capitol Ave., Jefferson City, MO 65101. Second-class postage is paid at Jefferson City, Mo. Copyright© 1998 by the Missouri Bankers Association. All rights reserved. POSTMASTER: Send address changes to The Missouri Banker, P.O. Box 57, Jefferson City, MO 65102. Opinions expressed in any signed article in The Missouri Banker are those of the author and should not be construed as the viewpoint of the editors or of the Missouri Bankers Association. Neither should information provided in The Missouri Banker be construed as legal advice. The Missouri Banker does not provide legal advice, nor does it take the place of legal counsel hired by financial institutions. While this publication makes a reasonable effort to establish the integrity of advertisers, it does not endorse advertised products or services, unless otherwise so stated. This issue may contain legislative advertising. Advertising copy is generally segregated from news and other information.
Address changes Changes in addresses for The Missouri Banker can be mailed to the MBA at P.O. Box 57, Jefferson City, MO 65102, Attn: Database Manager or e-mailed to email@example.com
delegation, starting the visits on Tuesday, Oct. 1, was full of uncertainty due to the government “shutdown.” Were the Representative’s and Senator’s offices going to be open? Were the various agencies going to honor our appointments for an audience? If open, what would security checkpoint lines be like with so many access points closed? What we found was a pleasant surprise! The lines weren’t bad. We were able to visit with eight of 10 members of the Missouri delegation. In the other two cases, we visited with the Legislative Director on staff. The great thing was we were able to visit for longer periods of time than normal. With them being out of session there were no committee meetings, no hearings and no votes to take. ABA briefing Our visit began with a tremendous briefing by the ABA. Mike Hunter, ABA COO, and Wayne Abernathy, EVP, Financial Institutions Policy and Regulatory Affairs, were joined by a host of ABA staff members who briefed us on the status of QM, Basel III, Bank Examination Reform, Community Bank Regulatory Relief, Credit Union Taxation, Farm Credit System Taxation, Housing Finance Reform,
In the September issue of The Missouri Banker,
Ron Rushing should have been listed as working for Marshfield Investment Company, the holding company for Metropolitan National Bank. We regret the error.
Patent Reform and much more. Needless to say, we were well prepared when we headed to our various agency and “hill” visits!! Meeting with agencies As for the agencies, it was business as usual. The “shutdown” didn’t seem to be affecting the FDIC, OCC, FED or CFPB. The only cancelation we experienced was our meeting with Treasury officials on our last day. CFPB The first agency visit on our schedule was with the CFPB. Agency meetings are always interesting and normally useful. This meeting didn’t let us down on the interesting side of things. The tone was set as we entered the theater style room. Our hosts were seated on the lower platform and asked us to be seated … no greeting, no handshakes, no small talk, just take a seat!! The four individuals from CFPB were Elizabeth Ellis, Deputy Assistant Director, Office of Financial Institutions and Business Liaison; Nicholas Hluchyj, Senior Counsel, Office of Regulations; Kitty Ryan, Deputy Assistant Director, Office of Regulations and Paul Sanford, Assistant Director, Office of Supervision Examinations. Knowing from previous briefings with other states that Qualified Mortgages/Ability to Repay (QM) would be high on our list of topics, they launched into their explanation of QM and proceeded to tell us that bankers would make non-QM loans despite the litigation risk that stays with that loan for life. We tried
to explain that community bankers wouldn’t take that risk and that without an exemption, consumers/borrowers would be harmed. (Our ask with CFPB, and everywhere we went, was to exempt portfolio loans from the QM rules and to delay implementation of the rules for one year to allow an orderly transition period to comply with the QM rule. Time is needed for banks to work with their vendors to develop and customize the software necessary to comply with this rule.) I am hoping that they will be moved by the cumulative effect of our comments and the efforts of the other state associations and ABA. Our discussions with the banking regulators regarding QM didn’t fall on deaf ears. It was apparent that they too had been visiting with CFPB about this issue. We asked them to please continue the dialogue in hopes of seeing some positive change take place. OCC At the OCC, they continued the theme that we heard during our regional meetings … Strategic Risk. They want banks to continually evaluate their current situation as compared to their strategic plan, as well as evaluating the risk profile of the present environment. They expressed concern that they are seeing some business models that include products that the banks have no expertise in. Congressional visits As I mentioned, the visits with our congressional members went very well. The one thing that I was extremely pleased with was the willingness of all four members of
our delegation, who are on Financial Services Committee, to write a joint letter to CFPB requesting an exemption from QM rules for portfolio loans as well as a one year delay in the implementation of the rules. The great news here is that before we could pull the trigger on such a letter, Reps. Shelly Capito (R-WV) and Gregory Meeks (D-NY), chairman and ranking member respectively, of the Financial Institutions and Consumer Credit Subcommittee, agreed to write a letter making the same requests of CFPB. All members of the committee, including our four, will have the opportunity to sign the letter. I think this underscores the importance of having bankers in DC, visiting with their delegation and making things happen. Moving our Financial Services Committee members and the banking regulators to visit with CFPB is BIG!!! My hat is off to each and every person who made the trip to DC. Dedicating the precious resources of time and money paid dividends. GR Summit set in spring I hope all Missouri bankers will consider making the same commitment this coming spring. MBA will be taking a group to DC on March 24 – 26 to take part in the ABA Government Relations Summit. Similar meetings with congressional members and regulators will take place at that time. In the meantime, I hope you will keep the dialogue going with our congressional members when they are home. The success we had in DC needs to continue.
The Missouri Banker October 17, 2013
Planning for the next Legislative Session Bill Ratliff Executive Vice President Missouri Bankers Association firstname.lastname@example.org Although the 2014 state legislative session is still three months away, we are already planning and preparing for it. In addition to meeting with lobbyists from other bankers associations at the State Issues Summit in Chicago, we continue to talk to bankers and lobbyists (and even some legislators!) about potential issues for next session. I’ve been keeping a “possibles” list of issues that might have to be dealt with next session. So far, I have 21 items on the list. If history is any judge, about two – thirds of these issues will pop up during the session and
one-third won’t, instead we will find ourselves involved in a few issues that we had not even considered before the session began. Our Legislative Affairs Committee meets Nov. 12 to review these and other issues that will likely appear in the next few weeks. We’ll set priorities and recommend positions for approval by the MBA Board meeting in early December. Housing Alliance For several years, MBA has been a member of the Missouri Housing Alliance. This is a group of associations somehow related to (you guessed it) housing. We
have quarterly meetings and discuss issues ranging from new state laws to the latest pest infestations in apartments. At almost every meeting I learn of some new issue or Craig and I get a new ally on some legislative issue. At the most recent meeting, the topics ranged from the newly passed foreign ownership of agricultural land bill (there are already some problems with it) to Brown Recluse spiders in homes and garages. Once the session begins, these meetings become really helpful because we see the range of issues that could Paid Advertisement
impact banks. Issues discussed at this latest meeting also included: drones, associate judgment liens, closing protection letters, and dry cleaning remediation. These are all now issues for our Legislative Affairs Committee to review. And now the meetings begin… I mentioned that we’ve had some meetings , but I really mean a LOT of meetings. Over the last few weeks, Craig and I have met with the Department of Agriculture, the State Treasurer’s office, the Division of Finance, bank lobbyists from around the country (at
the State Issues Summit) as well as individual legislators and a couple of community activists. These meetings are when the real work on the bills gets started. There is less time pressure and we can spend more time delving into the potential bills and (hopefully) get them into decent shape before the Legislature convenes. Once the session starts, things get a bit more messy as bills, amendments, and substitute bills start flying in all directions. That’s when mistakes are made. By working on these issues early just maybe we can eliminate some problems.
The Missouri Banker October 17, 2013
BASEL III and the S-corp banks
Bankers build houses for Habitat for Humanity St. Louis Bank executives from across the St. Louis metropolitan area will be building houses in University City as part of Habitat for Humanity Saint Louis’s Metropolitan Saint Louis CRA Associations (MSLCA) BUILD. The CRA BUILD will allow St. Louis bankers to work alongside their peers and have an opportunity to form business relationships while building homes and transforming lives for low-income families. Habitat has a home ownership program that builds and sells its homes to low-income, diverse partner families. These families partner by contributing 700 hours of sweat equity (350 hours for individuals) to build their homes and the homes of others, and then pay a zero-percent interest mortgage. The mortgage proceeds go back into building additional houses for other families. MSLCA is made up of banks and savings banks in the St. Louis MSA. David Noble of Midwest BankerCentre and chairman of the Metropolitan CRA Association Board of Directors will participate in the effort. He offers, “The MSLCA recognizes Habitat for Humanity Saint Louis for the great work they do in the community. Many of our members already have strong relationships with them. The CRA Association BUILD is an opportunity for our members to work together while showing our support for an organization that does vitally important work for St. Louis by helping people get into affordable home ownership.” Some of the member banks involved in the BUILD include: Carrollton Bank, Citizens National Bank, Commerce Bank, Commercial Bank-StL, Enterprise Bank & Trust, First Bank, First County Bank and First Collinsville Bank, First National Bank of St. Louis, Great Southern, Heartland Bank, Midwest BankCentre, Montgomery Bank, PNC, Regions Bank, Southern Commercial Bank, Stifel Bank and The Business Bank.
By Keith Thornburg MBA General Counsel Banks, as well as state and national banking associations and attorneys and other professionals who counsel banks on corporate and tax structures, will continue to advocate for changes to Basel III to address several provisions that have an unfair impact on S-corp banks because of their unique structure. By large measure, the primary concern is with the “capital conservation buffer” rule and how this could trigger the circumstance that S-corp shareholders could be forced to pay income taxes on the taxable income of the financial institution without receiving a distribution of any of the income. Regulators came up with the novel idea of a “capital conservation buffer” to automatically, and without supervisory intervention, place banks under capital conservation restrictions (even as they continue to meet capital requirements) by associating the additional buffer capital levels with distress. Essentially banks flag themselves with progressive sanctions upon filing of a call report that show capital levels below the buffer levels. To illustrate the problem, assume that a bank has taxable income of $1,000,000, and its capital is less than the required conservation buffer. Neither a C-corp nor an S-corp is allowed to make a distribution to shareholders, even though taxes are due on the income. However, if the bank is a C-corp, the bank would remit $340,000 directly to the US government to pay its Federal taxes.
If the bank is an S-corp, the shareholders, rather than the bank, would be required to remit approximately the same $340,000 to the US government to pay Federal taxes (the amount could be much higher depending upon the individual circumstances of the shareholders). Because triggering the conservation buffer rule prevents shareholder distributions – even for the purpose of paying federal income tax – the S-corp shareholders are forced to pay these taxes out of individual funds. The above example demonstrates that, effectively, a distribution is allowed to be made from the C-corp funds for the benefit of its shareholders, but a distribution is not allowed to be made from the S-corp funds for the benefit if its shareholders. The clash of tax and banking policies – is illogical and needs to be repaired. S-corp banks should be allowed to make distributions for the limited purpose of allowing shareholders to make tax payments on their share of the S-corp bank’s undistributed income, at least in an amount equal to the effective tax rate for C-corps. This is a very serious issue for S corporation banks and their shareholders. The preferred solution for this dilemma is for the banking agencies to make adjustments to the Basel III rules. Although the banking agencies decided not to address this concern in the final Basel III rules – the industry and our banking association will continue to work with the regulators and legislators to obtain relief on this issue for our Sub S member banks.
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The Missouri Banker October 17, 2013
Veto overrides have effect on banking in Missouri On Sept. 12, 2013, the members of the Missouri House and Senate voted to override the Governor’s vetoes on nine non-appropriations bills and one appropriation bill. The number of overrides is historically significant, but news media coverage was dominated by the Governor’s success in sustaining his veto of HB No. 253, which was the General Assembly’s tax reform and tax cut bill. House Bill 329 is of particular interest to Missouri bankers. Funeral trusts – at Section 208.010 (related to Medicaid law) is amended to allow individuals to establish an “Irrevocable personal funeral trust” with any financial institution authorized to exercise trust powers. The trust can be established in an amount up to $9,999. This amount is effectively set aside and protected from Medicaid spend-down and eligibility requirements. This is an express alternative to contracting with a “pre-need” company under Chapter 436. No “pre-need” contract is required
with any cemetery or funeral provider as a condition to establishing a funeral trust to fund burial and funeral expenses. Upfront fees cannot exceed 10 percent of the amount deposited to the trust account and administration fees cannot exceed three percent of the trust assets annually. Funeral trusts must be separately accounted but the trust funds can be co-mingled for prudent investment purposes. Any remainder in the trust after funeral and burial expenses are paid, will be paid to the State of Missouri to offset public assistance to the settlor (or designated beneficiary), and after this, the State of Missouri is required to refund the remainder to the settlor’s “successors” (Any remainder should probably be addressed in the funeral trust document to guide the state disposition). The option to establish a “personal funeral trust” could be a very convenient, safe and commission free option for your customers to set aside funds for their final expenses and to preserve these assets from Medicaid
spend-down requirements. The MBA staff and general counsel are reviewing this new product opportunity with bankers, trust officers and attorneys to consider “simple” form agreements and mechanisms to implement the trusts. Your local funeral directors could be very interested in seeing your bank provide this service in your community. Exam cycle for private trust companies – Section 361.160 was amended to allow the Division of Finance to extend the examination cycle for 1 or 2 rated “private” trust companies to 36 months (from 18 months). Private trust companies are typically “family offices” and thus do not offer trust services to the general public. Section 408.140.1(1) was amended for purposes of closed-end consumer loans of 30 days or longer to increase the allowable fee from 5 percent to 10 percent (the total $75 cap is retained). This section also presents the amendment to 408.140.1(10) increasing the allowable fee for
“deposit advances” to 10 percent (from 5 percent) not to exceed $75. This increase allows Missouri based banks parity with out-of-state banks that are already offering this product in Missouri. Consumers will benefit from having access to these small dollar consumer credit products that are strictly regulated by the bank supervisory agencies and the CFPB. The deposit advance portion of these changes, were also enacted in SB 254. State HMDA reporting and review – Sections 408.590 and 408.600 were amended (and Section 408.592 repealed) to eliminate duplicative HMDA-like reporting required in counties and municipalities with a population in excess of 250,000. This change was duplicated in SB 235. Protection of HSA’s and inherited IRA’s – Section 513.430.1(1) (f) was amended to treat these tax deferred accounts similarly to other tax deferred accounts for attachment and execution purposes. This change was duplicated in SB 100.
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The Missouri Banker October 17, 2013
Adventures of the Missouri No-Oral-Credit-Agreement Statute; Governor signs corrective amendment in SB 100 By John Walsh The Missouri credit agreement statute of frauds has had uneven interpretations by the courts. It has been amended twice to overrule appellate court decisions that limited its obvious intent, which is to eliminate all claims by borrowers and guarantors(or lenders) that oral promises or commitments had been made or breached or that there were representations at variance with written loan agreements, promissory notes, guaranties or similar documents. It was originally adopted as § 432.045, R.S.Mo., in 1990. In 1997 federal courts predicted that Missouri appellate courts would interpret the statute broadly to exclude all claims, including those claims or defenses based on fraud.But in 2003 the Missouri Court of Appeals in Mika v. Central Bank of Kansas City, 112 S.W. 3d 82
(Mo. Ct. App. 2003), limited the scope of the statute to contract-law claims and excluded claims or defenses based on allegations of fraud or equitable claims or defenses. In 2004, taking the guidance by the court in the Mika opinion, the Missouri General Assembly adopted a revised statute, § 432.047, applicable only to commercial transactions, that precluded a “debtor” (borrower, guarantor, mortgagor) from maintaining “... an action upon or a defense, regardless of legal theory in which it is based, in any way related to a credit agreement unless the credit agreement is in writing ...” [emphasis shows new language]. In 2011, a federal court again predicted that Missouri courts would hold that the revised statute would bar all tort as well as contract claims and defenses asserted by guarantors, who in that
case claimed that a lender had made oral promises to overlook the guaranteed borrower’s default, to negotiate existing loans and to extend loan maturity dates. U.S. Bank National Association v. Canny (Case No. 4:10CV421, E.D.Mo. January 24, 2011). Eventually, a Missouri appellate court addressed the revised statute and held that it was effective to negate all claims and defenses based upon allegations or oral promises, including those based on fraud or any other equitable doctrine. BancorpSouth Bank v. Paramont Properties, L.L.C., 349 S.W. 3d 363 (Mo. Ct. App., E.D. 2011). The assault on § 432.047, however, continued and, in mid-2012, § 432.047 was the subject of a limiting interpretation in Bailey v. Hawthorn Bank, 382 S.W. 3d 84 (Mo. Ct. App. W.D. 2012). In that case, the court of appeals held that a combination of a vague commitment letter, which did not contain basic terms such as interest rate and installment payment amounts, and an internal written loan summary, which did contain the relevant terms, together constituted a written “credit agreement,” as the term is used in the statute, even though internal loan summary was never delivered to the borrower. In response to that opinion, Senate Bill 100 revises §432.047 to make it clear that a credit agreement must not only be in writing, must provide for the payment of interest or other consideration and must set forth the relevant terms and conditions, but also must be “... executed by the debtor and the lender.” §432.047-2. Senate Bill 100 also adds the words “or unexecuted” to the first line of the language required to be inserted in
commercial credit agreements giving notice of the statute. As revised, the language reads as follows (must be in 10 point bold face type): ORAL OR UNEXECUTED AGREEMENTS OR COMMITMENTS TO LOAN MONEY, EXTEND CREDIT OR TO FORBEAR FROM ENFORCING REPAYMENT OF A DEBT INCLUDING PROMISES TO EXTEND OR RENEW SUCH DEBT ARE NOT ENFORCEABLE, REGARDLESS OF THE LEGAL THEORY UPON WHICH IT IS BASED THAT IS IN ANY WAY RELATED TO THE CREDIT AGREEMENT. TO PROTECT YOU (BORROWER(S)) AND US (CREDITOR) FROM MISUNDERSTANDING OR DISAPPOINTMENT, ANY AGREEMENTS WE REACH COVERING SUCH MATTERS ARE CONTAINED IN THIS
It’s a small world
WRITING, WHICH IS THE COMPLETE AND EXCLUSIVE STATEMENT OF THE AGREEMENT BETWEEN US, EXCEPT AS WE MAY LATER AGREE IN WRITING TO MODIFY IT. The revised language should be used in all commercial credit agreements and notes after Aug. 28, 2013. This amendment may not be the end of the adventures of the Missouri no-oralcredit-agreement statute. It appears that for every amendment to the statute there is a court challenge attempting to limit the clear intent of the statute. John Walsh is Of Counsel with Spencer, Fane, Britt & Browne, LLP in their St. Louis office. John practices in commercial transactions, secured lending, mergers and acquisitions, securities laws, and general business law. John is a member of the MBA Bank Counsel Section and frequently presents to attorneys and bankers in our programs.
Carol and Mike Williamson, Emprire Bank, Springfield (left) and Gretta and Bill Ratliff of the MBA were wandering around the second floor of a shopping market in Budapest, Hungary, when they ran into each other. The two couples were on separate river cruises and just accidentally ran into each other in the market.
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And you thought Noah had problems with FLOOD! By Rob Hoff, CRCM Vice President Compliance Services In 1968 the Congress created the National Flood Insurance Program to make affordable flood insurance generally available to home and business owners. 45 years later the flood risks continue, the costs of flooding continue to rise, and the government is coming to the rescue (again!). This is primarily due to Hurricane Katrina in 2005 and Super Storm Sandy last year, as the National Flood Insurance Program (NFIP) is in the hole about $24 Billion now. And Noah thought he had problems with building an ark to save the world from the big flood?!?!? (Well, okay, maybe these changes are not as big as all that, but it still got you to read this far, right?) So back to the article, in 2012 the Congress passed legislation to make the program more sustainable and financially sound over the long term through the Flood Insurance Reform Act of 2012, also known as Biggert Waters 2012. What has changed? Many property owners in flood hazard areas will see their flood insurance costs increase – some immediately, some later. In general, the rates for flood insurance for most properties will more accurately reflect the risk of flooding on an actuarial basis, and the government subsidies that have been in place for years will be phased out. The non-primary residence flood insurance rate subsidies are being phased out now. Effective 1/1/2013, non-primary residence property owners will see a 25% increase annually until the rates reflect the true risk. Some have estimated that insurance premiums will more than double over the next 5-6 years as this new legislation is phased in. FEMA defines a principal or primary residence as a single-family dwelling in which, at the time of loss,
the named insured has lived in for 80% of the period of ownership. Primary residence flood insurance rate subsidies will continue for a while, but will be phased out sometime in the next year or two – FEMA has not announced a phase out timeline yet. Owners of subsidized properties that have experienced severe repetitive flood losses, or that have incurred flood cumulative damage with flood insurance payments exceeding the value of the structure will see a 25% rate increase annually until the rates reflect the true risk – beginning 10/1/13. Examples given by FEMA for severe repetitive losses include: • 4 or more separate claim payments of more than $5,000 each OR • 2 or more separate claim payments where the total value of the payments exceeds the current market value of the property The Preferred Risk Policy (PRP) Eligibility Extension allows structures mapped into Special Flood Hazard Areas (SFHAs) on or after 10/1/08 to remain insured at the lower PRP rates. However, policies with the PRP Eligibility Extension will see average annual increases of 20% beginning 10/1/13. If the flood insured property is in a community which has adopted the new, updated Flood Insurance Rate Map (FIRM), the insurance premiums based on a prior FIRM (or grandfathering) will be phased out. The implementation date of this phase out process has not been announced by FEMA. Another caveat is the purchase or sale of a property, or allowing a policy to lapse, may trigger rate changes due to the loss of grandfathering provisions. Who is not affected by the subsidy changes? Owners of primary residences in SFHAs will be able to keep their subsidized rates
unless or until: • The property is sold (new rates will apply to the next owner if they insure) • The policy lapses • The property suffers severe, repeated flood losses OR • A new policy is purchased after 7/6/12 Reserve Fund The legislation required a reserve fund to be established to pay for future losses. A 5% premium increase will go toward the reserve fund (except for PRP policies and Group Flood Insurance Policies). The Pre-FIRM premium increases related to the phase out of subsidies and discounts already include the 5% reserve fund increase. What can primary residential owners with required flood insurance do? First, if they have required flood insurance in place now, strongly encourage the customer to keep the existing policy current. This will save some premium costs until FEMA implements the mandatory increase over the next year or so. Also, if a customer has not had an elevation survey completed by a licensed surveyor, this can reduce the future premiums by assisting with the risk assessment by the insurer. For instance, the flood insurance premium on a property that is 4 feet below the base flood elevation will be as much as 22 times the cost of a property that is located 3 feet above the base flood elevation. So elevation surveys can help reduce the cost – saving thousands of dollars in premiums over the life of home ownership and financing. And new construction should consider moving the house further away from the flood hazard area, if at all possible. So, how does this impact banks? Undoubtedly banks will have to explain these changes to affected customers- es-
pecially when they receive premium increase notices from their insurer. And banks should increase monitoring of existing policies to be sure they don’t lapse which causes the rate increases to be effective immediately with the new policy. Also, and just as important, the penalties for non-compliance by banks has increased. The maximum civil money penalty for a FDPA violation has increased to $2,000 per violation with no annual penalty cap. Most of this information was taken from a presentation by a FEMA representative at the MBA Compliance Conference held in September 2013. More information is available from http://www. fema.gov/flood-insurancereform-act-2012. The FDIC, OCC, Federal Reserve, Farm Credit Administration and NCUA have issued a joint notice of proposed rulemaking implementing the 2012 Biggert-Waters flood insurance reform law. The proposal amends regula-
tions on loans in designated flood zones affecting escrows of insurance payments, acceptance of private flood insurance and force-placed flood insurance. Comments on the proposal are due Dec. 9. Efforts are also underway in Congress to delay some of the premium increases. So stay tuned! This article is for information purposes and does not contain or convey legal advice. The information should not be used or relied upon in regard to any particular situation without consultation with your bank attorney. MBA Compliance Services and its Compliance Force program offer a variety of programs to aid banks with compliance needs. Services available include on-site education, in-bank training, compliance reviews and loan review. For more information, call Carol Barnett at the MBA at 573-636-8151 or email her at cbarnett@ mobankers.com.
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The Missouri Banker October 17, 2013
Washington Visit In photo at right, Congressman Lacy Clay, second from right visits with, Ken Littlefield, from left, Molly Hyland, Max Cook and Larry Harris in his office. In photo below, Rodney Shepard, left, and Keith Monson were among the MBA members who took part in the Washington Visit. In photo at lower right, Tim Thompson, and Dan and Dianna Robb were part of the 2013 Washington Visit.
MBA Compliance Conference draws big crowds Over 200 bankers attended this year’s compliance Conference at Tan-Tar-A Resort September 18-20. For any one that attended our first conference back in 1993 it may have seemed like déjà vu. Denny Deischer and Chuck Lewis spoke then and they were back again along with a variety of familiar topics like RESPA, Reg Z, Fair Lending and compliance management. But, there were more new issues and problems that reflect today’s fast-changing banking environment . Bankers heard programs on Social Media, Dodd-Frank rules, Flood Insurance issues as well as regulatory updates from Missouri and Washington, D.C.
Ryan Bell, CEO, Gremln, Inc., an MBA endorsed business partner talks about social media compliance concerns at the Sept. 18 general session at MBA’s Compliance Conference.
Among the bankers taking part in the 2013 MBA Compliance Conference are, from left, Debbie DeBourge, Bruce Griffith and Linda Feldmann, all from The Mercantile Bank, Louisiana.
Chuck Lewis, left, vice president, MBA Compliance Services, and Denny Deischer, vice president, MBA Educational Services, discuss fair lending at the closing session of the 2013 Compliance Conference.
The Missouri Banker October 17, 2013
You do NOT have to be a member of the American Bankers Association to use Amplify. It is available to every banker. Just use your e-mail address to log in and you will be emailed a password.
About twenty years ago…
MBA introduced our little “Speak Out!” character to encourage bankers to become more vocal about the good things the banking industry does for local communities. We provided sample letters and Op-Ed pieces, statistics on a variety of issues, and even some sample speeches. Consider that an introduction to the new Amplify program from the ABA. With better technology and more electronic communications programs, Amplify is a very good successor to our original MBA program. The basic message however, is still the same….”Speak Out! (and use Amplify to help you do so loud and often! )
Amplify is here!
Amplify is a new hybrid program that combines Communications and Grassroots! It is aimed at helping bankers promote the work they are doing in their communities. Grassroots PR The point of Amplify is to help bankers focus attention on the many good works they do rather than letting bad news out of Washington or New York define banking to the folks back home. How does it work? Amplify uses a simple website that will help bankers navigate their grassroots activities:
• Need a speech? Amplify can help! • Planning a bank tour for a congressman? Amplify can help! • Getting into Social Media? Turn to Amplify!
The centerpiece of Amplify is a simple website that directs you to specific topics…bank tours, speeches, Social Media, etc.
Current issues Keep up on current issues impacting your bank and be able to discuss them with customers, news media and legislators. Here is the list of Current Issues now being highlighted at Amplify:
Plain language talking points Credit union tax reform Basel III capital rules Regulatory Relief for community banks • Examination bills • • • •
Who is it for? Amplify is for any banker who wants to share his or her story about what it means to be a banker today.
Some key messages from Amplify Whether you are planning a news release or an in-bank visit by everyone from school kids to congressional delegates, Amplify will provide you with simple, easy-to-follow suggestions and guidance. Here are some “Key Messages” that Amplify repeats over and over:
• There is no place more safe and secure to keep your money than your local bank. • Banks are partners in their local communities. • Banks are the largest suppliers of credit to farmers and ranchers. • Not a penny of FDIC-insured bank deposits has ever been lost. Go to amplifybankers.com for more Key Messages.
Sign up for Amplify! It is quick and easy to sign up for Amplify. Just go to ampliyfybankers.com and hit the “register” key. You will be asked for your bank e-mail address and to create an individual password. You’ll get an e-mail confirmation within seconds. That’s it. You are now registered to use all the elements of Amplify available to you and your bank. We suggest you register and then browse through the various options you will be given. We think you will find Amplify to be a very helpful online tool.
The Missouri Banker October 17, 2013
Agenda October 2013
IRA Seminar, Cape Girardeau
IRA Seminar, Columbia
Security Management Seminar, Columbia
IRA Seminar, Springfield
IRA Seminar, Kansas City
24 - 25 Bank Legal Issues Conference, Holiday Inn Executive Center, Columbia 29 AIB Principles of Banking Two-Day & Nov. 5 Class, Independence 31
Directors Forum, Stoney Creek Inn, Columbia
November 2013 1
Compliance Issues for Lenders Webinar, 10 a.m.
Bank Secrecy Act Seminar, Columbia
QM/ATR Drill Down Seminar, Columbia
20 -21 Lending Compliance Workshop, Columbia December 2013 4-6
Executive Management Conference, The RitzCarlton Hotel, St. Louis
January 2014 11 - 19 Senior Bank Management Conference, St. Lucia 19 - 24 School of Bank Management, Stoney Creek Inn, Columbia March 2014 3 - 7
School of Compliance, Stoney Creek Inn, Columbia
8 - 14
School of Lending, Stoney Creek Inn, Columbia
11 - 13 Graduate School of Lending, Stoney Creek Inn, Columbia
MBA is a part of Regulatory Feedback Initiative (RFI) The MBA has joined with bankers associations across the country to create the Regulatory Feedback Initiative (RFI). This initiative will bring transparency and accountability to the regulatory process and will help every bank in the country prepare for their examinations and manage their regulatory risk. Â The initiative consists of a brief, anonymous online survey that we are asking every bank to take immediately following each safety and soundness examination and each compliance examination.Â We need every bank to build the survey into their examination process. For more information, visit the Alliance of Bankers Associations web site at www.allbankers.org. To receive a link to the survey contact Mike Noblett at the MBA via email at email@example.com.
The Missouri Banker October 17, 2013
Pony Express Bank, Braymer; Bank of Grain Valley make strong bank list in KC area Kudos to Pony Express Bank, Braymer, and the Bank of Grain Valley for making the Kansas City Business Journalâ€™s list of the top five strongest banks in the Kansas City area! Using their own criteria the Business Journal cited Pony Express Bank for its focus on the Northland area, and Bank of Grain Valley for its strong capital position. The Journal criteria were based on Core Capital Ratios, Problem Loan Ratios, Equity Capital, and the Texas Ratio. A number of other Missouri community banks received honorable mentions.
Compliance Issues webinar set for Nov. 1 Chuck Lewis, vice president, MBA Compliance Services is presenting a webinar on Compliance Issues for lenders. It will be held at 10 a.m. CDT on Friday, Nov. 1. The class will last about one hour and will give an overview of the Dodd-Frank/ CFPB issues that affect every bank. For more information, visit www.mobankers.com.
Now Hiring Experienced Ag/Commercial Lender for Springfield, MO (including outlying communities). This position will require advanced knowledge of complex commercial lending. Applicants are required to have 3-4 years of previous agriculture lending related experience with emphasis in evaluation/origination of complex credits. To review the job description and apply, please visit: www.arvest.com We Offer Competitive Salary, 401K, Health Benefits, Profit Sharing Bonus, Paid Time Off and Paid Holidays. All applicants must pass a consumer credit check, drug screen, and FBI background check. For more information, call 417-885-7253 or email firstname.lastname@example.org EEO/AA
Now Hiring Experienced Commercial Lender for Lebanon, MO. This position will require advanced knowledge of complex commercial lending. Applicants are required to have 3-4 years of previous commercial lending related experience with emphasis in evaluation/origination of complex credits. To review the job description and apply, please visit: www.arvest.com We Offer Competitive Salary, 401K, Health Benefits, Profit Sharing Bonus, Paid Time Off and Paid Holidays All applicants must pass a consumer credit check, drug screen, and FBI background check. For more information, call 417-885-7253 or email email@example.com EEO/AA
Now Hiring Experienced Commercial Loan Manager for Springfield, MO. This position will require advanced knowledge of complex commercial lending. Applicants need to have a minimum of 10 years of commercial lending experience & 2 or more years of supervisory experience. To review the job description and apply, please visit: www.arvest.com We Offer Competitive Salary, 401K, Health Benefits, Profit Sharing Bonus, Paid Time Off and Paid Holidays All applicants must pass a consumer credit check, drug screen, and FBI background check. For more information, call 417-885-7253 or email firstname.lastname@example.org EEO/AA BANK OF MONTICELLO is currently seeking a Branch Manager for its Canton, MO location. Responsibilities will include day to day management of the branch, supervision of branch staff, business development within the Canton market area, consumer lending and monitoring branch activity to meeting profit and growth goals. A business degree or significant experience in banking is preferred. Salary will be commensurate with experience. Send resumes to Bank of Monticello, Attention: Virgil Welker, President, P. O. Box 38, Monticello, MO 63457.
Deadline to place a classified advertisement in The Missouri Banker is five days prior to publication date. Email ads to email@example.com and an invoice will be mailed to you. Logo insertion charge, $12.50. Classified advertisements are posted on the public side of the MBA Web Site at no extra charge for the same time period as advertised in The Missouri Banker. Classified ad rates are as follows: $1.00 per word for one issue $1.50 per word for two issues $2.00 per word for three issues
Two Missouri Bankers graduate from GSB at LSU Two Missouri bankers have graduated from the Graduate School of Banking at Louisiana State University. They are: Andii Jobe, assistant vice president/operations manager at Midwest Independent Andii Jobe Matthew Drake Bank (MIB), Jefferson City, and Matthew Drake, North Market senior lender with First State Bank and Trust Company, Sikeston. Jobe has been with MIB since 2004, and Drake has been with First State Bank for six years. Paid Advertisement
The Missouri Banker October 17, 2013
MBA Title Service “indispensable” to bank’s operation
“MBA Title Services is a very valuable resource for United Bank of Union. Linda Petersen and her staff are extremely helpful when we Dawn Olive contact them for assistance with title problems. Their response time has been outstanding and our bank staff has always been treated in a very professional and courteous manner. We have had some complicated titling issues involving the Department of Revenue and had it not been for the assistance of MBA Title Service we may have experienced longer delays in perfecting our lien. We believe that our association with MBA Title Service is indispensable to our bank’s operation!” Dawn Olive United Bank of Union
“Pony Express Bank has been an active user of the MBA’s Title Service for well over 10 years. Linda and staff are very knowledgeable and can Pam Swope answer any questions we may have. The biggest advantage to using the title service is the quick answers to your questions—you don’t have to be on the phone for hours—like you would if you called the local DMV or Department of Revenue. We send all of our titles to the MBA for processing. If there is a problem, they catch it before hand - delivering to the DOR. We would highly recommend figuring the title service into your next year’s budget.” Pam Swope Pony Express Bank “We have been with MBA for years and Linda has always been so helpful! If she didn’t know the answer at
the time of our call she would always get to the bottom of the problem in a timely fashion. Thank you Linda for being so helpful and nice!” Jean Shippy F & C Bank
Call for answers
“We depend on the MBA Title Service for those out-of-the-ordinary titling problems. They are quick to get back to me with the answers and to resolve any issues to ensure our lien is properly secured. The titling rules and procedures are ever-changing and MBA is always there to notify you of these. On average, I file more than 300 liens per year and Cathy Wade could not do my job well without their help.” Cathy Wade Ozark Mountain Bank
Members of the MBA Title Service can call us at any time and we will answer your questions quickly and accurately. You can also fax or email us your questions. The biggest advantage to MBA Title Service members is quick answers that are geared to what you need as a lender. We are the only ones to offer answers from your point of view. The DOR is not always familiar with what the lender needs. You must be an MBA member to join the MBA Title Service. Membership fees are based on your asset size. Just call me, Linda Petersen, Title Service Manager at 573-6368151. I’d love to talk with you about joining the MBA Title Service team.
MBA Title Service at YOUR service
Community banking in the 21st Century The Federal Reserve Bank of St. Louis hosted a community bank “research conference” in St. Louis Oct. 2-3 that was titled “Community Banking in the 21st Century.” In preparation for this conference, the St. Louis Federal Reserve solicited research papers last spring. Also, state banking commissioners were asked to hold community bank “town hall” meetings. Missouri Division of Finance Commissioner, Rich Weaver, did just that with assistance from both the MBA and MIBA. Missouri bankers responded heartily with 250 town hall attendees, more than any other state attendee response. The Conference of State Bank Supervisors supported and helped facilitate the conference. Missouri bankers attending the conference included Peter Benoist, Enterprise,
Bank, St. Louis; John Klebba Legends Bank, Linn; and and Mike Poland. Farmers State Bank, Cameron. The Missouri Division of Finance was represented by Commissioner Weaver and Deputy Commissioner Debra Hardman. The MBA’s general counsel, Keith Thornburg, also attended. The conference attendees included community bankers from across the country, state regulators from across the country, university and college academics and federal regulatory and research staff from several of the Federal Reserve Banks. Federal Reserve Chairman Ben Bernanke helped kick off the conference Wednesday with opening remarks. Federal Reserve Governor Jerome Powell delivered a keynote address on Thursday that overviewed the 12 research papers that were
presented at the conference. Governor Powell’s remarks included an announcement that Federal Reserve will modify its consumer compliance supervision program for community banks in 2014 to “base the examination intensity more explicitly on the individual bank’s risk profile, including its consumer compliance culture and how effectively it identifies and manages consumer compliance risk.” Hopefully this translates into common sense regulatory relief. Governor Powell’s remarks indicated that federal policies and rulemakings are open to further refinement to take into account the interests of community banks and their customers’ needs and the competitive challenges facing community banks. Governor Powell stated: …. many of the asset
classes that traditionally comprised much of community bank portfolios have faced increasing competition in recent decades from firms that operate at the national level. As auto, mortgage, and credit card loans have become increasingly standardized, community banks have had to focus to a greater extent on small business and commercial real estate lending--products where community banks’ advantages in forming relationships with local borrowers are still important. These are not cheap or easy loans to make, and the loss of some traditional product lines has threatened the stability of some community banks. It is incumbent on the Federal Reserve and other regulators to understand the challenges community banks face
and to ensure that our regulatory policies do not exacerbate them. The conference closed with a panel discussion and questions with four community bankers presenting distinct business models and customer bases, but all were focused on the “soft capital” advantage that community banks call “relationship” banking. Because of the apparent success of the conference, it will likely be duplicated in future years. Governor Powell’s overview and closing remarks can be viewed at: http://www.federalreserve.gov/newsevents/ speech/powell20131003a. htm More information about the conference can be viewed at: http://www.stlouisfed.org/ banking/community-bankingconference/abstracts.cfm
The Missouri Banker October 17, 2013
Page 13 Paid Advertisement
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The Missouri Banker October 17, 2013
CFPB finalizes revisions to mortgage rules
The CFPB has approved several final revisions to the mortgage rules taking effect in January. The changes include provisions related to loan origination, rural and underserved areas, thresholds for points and fees and servicing. The revisions, among other things, clarify that tellers and other staff will not be considered loan originators “for merely providing loan originator or creditor contact information to the consumer, provided they do not direct the consumer to a particu-
lar loan originator or creditor based on an assessment of the consumer’s financial characteristics or discuss particular credit terms. This is a significant change that the banking industry had advocated. The final rule also clarifies that monthly insurance premium structures are not covered by the loan originator compensation rule’s ban on financed premiums. The banking industry had objected to language in the preamble of the original rule suggesting that pay-as-you-go pre-
miums were covered, and they were instrumental in persuading the CFPB to adopt this fix. The rule also extends to all small creditors, regardless of whether they operate in a predominantly “rural” or “underserved” area, the exemption from the ban on high-cost mortgages featuring balloon payments, so long as the loans meet certain restrictions. Similarly, the rule makes it easier for certain small creditors to continue qualifying for an exemp-
Missouri Division of Finance updates anti-redlining lobby poster The Missouri Division of Finance has updated the Anti-Redlining lobby poster required to be posted in accordance with Section 408.580.5 of Missouri law. This is the state notice regarding real estate applications that should be posted in the lobby of each office of state-chartered banks. The lobby poster was changed as a result of legislation passed this past session that repealed duplicative residential real estate reporting requirements for banks located in counties and municipalities with a population over 250,000. Joe Crider, Supervisor of Consumer Credit, Missouri Division of Finance,
spoke in detail about this requirement at last week’s MBA Compliance Conference. He stated that banks won’t be cited for failure to post the new notice any time soon. However, it’s recommended that each state-chartered bank begin the process of acquiring the new poster so it can be included with the other banking related notices displayed in your lobby. The updated poster may be obtained by calling the Missouri Division of Finance at 573-751-3242. You may also request a copy of the poster via their website or directly from Joe Crider at firstname.lastname@example.org.
Actions An application was filed with the Missouri Division of Finance for an interim bank charter for the proposed ADB Interim Bank, 651 N.E. Coronado Dr., Blue Springs. An application was filed for approval of a plan of merger of The First National Bank of Carrollton, Carrollton, with and into Bank 21, Carrollton, the surviving institution, under the name of Bank 21. The main banking house of the surviving bank will be the present main banking house of Bank 21. Permission was granted to Town & Country Bank, Salem, to relocate its already established branch from 115 NW 12th Ave., Ava, to Highway 5 and 14, Ava. Heritage Bank of the Ozarks, Lebanon, requested permission to establish a separate branch at 226B E. Highway 54, Camdenton. First Midwest Bank of Poplar Bluff, Poplar Bluff, received permission to establish a separate branch at 1215 Fellows Place, Columbia. Bank of Sullivan, Sullivan, requested permission to relocate an existing branch from 12747 Olive Blvd., Suite 385, St. Louis, to 16141 Swingley Ridge Road, Suite 201, Chesterfield.
QM/ATR seminar set for Nov. 19 Revisions to the new Qualified Mortgage (QM) and Ability to Repay (ATR) mortgage rules will go into effect in the next few months. Because of requests from our membership, MBA has scheduled a half-day seminar on Nov. 19 to discuss the new requirements. The seminar will be held from 1 to 4 p.m. at Stoney Creek Inn, Columbia, and is being taught by Denny Deischer, vice president, MBA Educational Services. Visit the MBA website at www.mobankers.com for more information or call the MBA at 573-636-8151.
tion from a requirement to maintain escrows on certain higher-priced mortgage loans. These expanded exemptions will remain
in place while the CFPB re-examines the underlying definitions of “rural” or “underserved” over the next two years.
The Missouri Banker October 17, 2013
Achievements Jeff Elsea has retired after a 38-year banking career with Bank of Westion. He began as a teller at the bank and worked his way up to president. Brandie Spanton was promoted to operations manager at the Mountain Grove branch for First Home Savings Bank. She has more than 10 years of banking experience. Kyle Langham has joined First Home Savings Bank as the operations manager for the Springfield branch. He has more than five years of banking experience. Tyrell Molleck was promoted to assistant vice president and bank manager for the Crane branch of First Home Savings Bank. He has more than five years of banking experience. Tera Mathewson was promoted to operations manager for the First Home Savings Bank Crane branch. She has more than nine years of banking experience.
Heartland Bank, St. Louis, recently announced five promotions. Amy Armstrong was Sarah Naunheim named vice president, compliance officer. Jaime Cotton was named assistant vice president, mortgage closing
supervisor. Robin Fogg was promoted to assistant vice president, loan business line platform manager. Sandi Kern was named assistant vice president, MISER platform manager. Sarah Naunheim was promoted to assistant vice president, processing supervisor. Melissa Smith joined The Bank of Missouri, Columbia, as a financial planning officer in the Melissa Smith Investment and Retirement Planning Division. She has worked with Fortune 500 companies as the lead financial planner. Darline Mabins has joined Metropolitan National Bank, Springfield as assistant Darline Mabins vice president, banking center manager. She will manage the Glenstone Banking Center. She has 11 years of experience in banking. Mark Wofford was named vice president, director of compliance risk management for BancMark Wofford Star, Inc., St. Louis. Brandi McWilliams has joined Guaranty Bank, Springfield, as a retail banking officer and Brandi McWilliams manager of the banking center located at 1510 E. Sunshine in Springfield. First State Bank of St. Charles announced the appointment of Mike Potter
and Jennifer Bouquet to its Advisory Board. Potter is a farmer partner at Trabue Industrial Systems in St. Louis. He is a former mayor of Lake St. Louis. Bouquet is president of J & J Boring, Inc., a Winfield, MO, company that specializes in boring, tunneling and pipe jacking. Tom Engler was promoted to vice president, consumer lending at Heartland Tom Engler Bank, St. Louis. He has been with the bank since 1995. Connie Stratman was promoted to vice president, manager of consumer residential Connie Stratman loan servicing, at Heartland Bank. She joined the bank in 1999.
Diann West was promoted to assistant vice president, mortgage platform manager, Diann West at Heartland Bank. She began at the bank as a consultant in 2004 and became a permanent employee in 2008. Shawn Ortwig was promoted to assistant vice president, junior commercial lender and Shawn Ortwig analyst, at Heartland Bank. He joined the bank in 2008. Patti Silvey was promoted to vice president, retail banking/branch manager at First State Bank of St. Charles. She has 34 years of banking experience. Renee Vogelgesang was promoted to assistant vice
president, business development at First State Bank of St. Charles. She has 14 years of banking experience. Matthew McBride was promoted to assistant vice president, mortgage loan service manager at First State Bank of St. Charles. Shaun Overton was promoted to mortgage information systems officer at First State Bank of St. Charles. He has worked in banking for 10 years. Lorna Creech was named customer focused banking coordinator for Arvest Bank Lorna Creech in Springfield to teach Arvest Bank culture and customer service. She will work at the Republic Road location. She has worked in banking since 1992.
Section 125 Cafeteria Plan Administration • Employees withhold a portion of their salary on a pre-tax basis to cover the cost of qualifying insurance premiums, medical expenses and dependent care expenses. • Auto Adjudicated Health and Prescription Claims. • By using tax-free dollars to pay for qualified expenses, your employees increase their spending power as well as their tax savings. • Employer payroll tax reduction as FICA taxes do not have to be paid on elected employee deductions. Your business can save 7.65 cents for every dollar contributed.
• $4 per participant / month
Call 800-234-4939 today for your enrollment packet.
The Missouri Banker October 17, 2013
GENERAL SESSION SPEAKERS Re-Visioning Retirement: New Timing, New Purpose, New Planning, New Funding Dan Veto Age Wave Emeryville, California
Financial Services Roundtable U.S. Representatives Invited to Speak Moderator James Ballentine Congressional Relations & Public Policy American Bankers Association
Credit Culture and Competitive Advantage Jeff Judy Jeff Judy & Associates Bloomington, Minnesota
Update on Community Banking & Regulatory Issues
Hotel Information _____________________
Insure your hotel accommodations NOW by making your reservations TODAY! The conference will be held at The Ritz Carlton Hotel. The room rates are: Deluxe Room .................................. $209.00 Executive Suite ............................... $284.00 Club Level Room ............................ $284.00 Reservation requests must be received no later than November 4, 2013 to receive the group rate. Reservations can be made: By phone at 314-863-6300 - Ask for the reservations department and indicate you are attending the Missouri Bankers Association’s Executive Management Conference.
U.S. Representative Blaine Luetkemeyer 9th District of Missouri
U.S. Representative Emanuel Cleaver 5th District of Missouri
U.S. Representative Wm. Lacy Clay 1st District of Missouri
U.S. Representative Ann Wagner 2nd District of Missouri
James Bullard Federal Reserve Bank of St. Louis St. Louis, Missouri
Innovation is Everybody’s Business Robert B. Tucker The Innovation Resource Santa Barbara, California
SPECIAL INTEREST SESSIONS International CyberCrime: Wire Fraud
Visit the MBA’s website at www.mobankers.com for a conference brochure or to register online or call MBA at 573-636-8151.
QM & Other Compliance Hot Topics Evolving Branch Models Affordable Care Act: Health Care Considerations
REGISTRATION FORM - MBA Executive Management Conference - December 4-6, 2013 Please PRINT or TYPE appropriate section(s) below. You may photocopy this form for additional registrants. Please enter the information below EXACTLY as you wish it to appear on your name badge and registration list.
Organization Information Bank/Firm _____________________________________ Address _______________________________________ City/State/Zip __________________________________ Phone_________________________________________ Fax___________________________________________
DISCOUNT - Payment by Check or Invoice #_______Members #_______Non-members #_______Spouse
@ $510 @ $900 @ $250
Purchase your “Wall of Wine & 99 Bottles of Beer +1” Raffle Tickets prior to the conference to benefit the Missouri Bankers Foundation. #_______“Wall of Wines” Raffle Tickets 6 for $100 #_______“Wall of Wines” Raffle IndividualTickets $20 ea. Total amount due
Invoice the bank.
Ways to Register
By Phone - Call 573-636-8151
*Spouse must be registered to attend conference events.
@ $530 @ $990 @ $275
Total amount due
By Mail - Mail your check PAYABLE to: Missouri Bankers Association P.O. Box 57 Jefferson City, MO 65102
$_________ $_________ $_________
Purchase your “Wall of Wine & 99 Bottles of Beer +1” Raffle Tickets prior to the conference to benefit the Missouri Bankers Foundation.
By FAX - Complete and fax to 573-634-2754.
Online - www.mobankers.com
#_______Members #_______Non-members #_______Spouse
#_______“Wall of Wines” Raffle Tickets 6 for $100 #_______“Wall of Wines” Raffle IndividualTickets $20 ea.
Check enclosed, payable to MBA.
Name of Attendee
$_________ $_________ $_________
Payment by Credit Card
$_________ $_________ $_________
Exp. Date__________________________________ No. _______________________________________ Type Name _________________________________ Signature __________________________________