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    TOO

    TO

    icba.org

    THE SPIRIT OF ENTREPRENEURIAL BANKING IN AMERICA

    Plus:

    Innovative Ad Campaigns

    Strategic-Planning RoundtableOptimizing Efficiency Ratios

    CONGRESS IS POISED TO TAME THE DINO-BANKS

    ntents | Zoom in | Zoom out Search Issue | Next PageFor navigation instructions please click here

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    2009 Goldleaf Financial Solutions, Inc. All rights reserved.

    Visit our RDC resource center at www.goldleaf.com/remotedepositexpert

    to access event listings, product information and thought-leading reference

    materials, including our white papers and relevant industry articles.

    Its all about the connection. Putting your bank at your customers ngertips and on

    their desktops through electronic remote depositsat any time, from any location

    simply attaches valuable customers to you. Remote deposit capture (RDC) is the

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    STICK WITH USTHEYLL STICK WITH YOU

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    ________________

    _____________________

    mailto:[email protected]://www.promnetwork.com/http://www.promnetwork.com/mailto:[email protected]
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    ICBAIndependentBanker 35

    OUT

    Gettin

    gtheWo

    rd

    ByAlanLenhoff

    ICBAIndependent BankerAdvertising All-Stars

    F U R V V Y M M UN IT Y B N K U E V R IE T Y F RE T I V E MRK E T IN

    IDEASAND MEDIATO CREATE TOP-NOTCH ADVERTISING CAMPAIGNS

    35

    Doing business with-out advertising is like

    winking at someone

    in the dark. You know what youare doing, but nobody else does.

    Its not clear who said that

    first, but any business that offers

    products or services, includingcommunity banks, can appreci-

    ate the sentiment.

    IC BA Independent Bank er chos efour commun ity ba n k

    advertising campaigns to spot-

    light for their creativity and

    effectiveness as part of its annualadvertising showcase. Each cam-

    paign reflects different goals,

    philosophies and creativity. Onecampaign is by a 157-year-old

    community bank; another bank

    was chartered in 2005. A third

    bank seeks a bigger footholdin mortgage lending; a fourth

    strives to solidify dominance in

    small business lending.What all four campaigns have

    in common is creative but rigor-

    ous marketing strategies imple-

    mented through a variety ofapproaches. Every community

    bank is unique. So is every Main

    Street market. No one marketingstrategy or advertising campaign

    i s un i v er s a ll y a ppl i ca bl e. But

    as these advertising campaignsshow, creativity and dedication

    can help any community bank

    increase its impact and market

    share.

    OUT

    TOO TO

    F I N A N C I A L R E G U L A T O R Y R E F O R M

    Financial regulatoryreform leg-islation aiming to subdue sys-

    temically dangerous, sometimes

    predatory institutions is in thea r ms ofC on g r ess .Thi s mon th

    con g r es s i ona l l ea der s, fr es hfrom town hall meetings during

    an August recess and after sev-

    eral summer hearings on the

    Obama administrations blueprint for change, planto roll up their policymaking sleeves to fashion

    together a consensus over a catalog of complex and

    potentially far-reaching proposals that could leadto final legislation.

    22 ICBAIndependentBanker

    We should not be forced to choose between allowinga company to fall into a rapid and chaotic dissolution

    or supporting the company with taxpayer money.That is unacceptable. There is too much at stake.

    P B OJ

    THE ERA OF TOOBIGTOFAIL FINANCIAL INSTITUTIONS, WHEREGIANT DINOSAUR BANKS AND NONBANKS WERE ALLOWEDTO FEAST AND GROW WITH ABANDON, COULD BE IN ECLIPSE.

    CONGRESS SETS OFF TO TAME THE DINO-BANKS

    By Steve Verdier

    ICBAIndependentBanker 23

    2 ICBA IndependentBanker September 2009

    contentsCOVERSTORY

    Making DangerousDino-Banks Disappear

    Congress is looking to find a consensus this

    fall on the historic financial regulatory reform

    legislation, a crucial opportunity for America

    to end too big to fail. Review the state of play

    for the financial reform legislation, ICBAs

    core principles on the issue and how your

    community bank can get involved.

    BY STEVE VERDIER

    22

    9

    11

    12

    50

    52

    54

    16

    18

    FEATURES

    Getting the Word OutFour innovative advertising and

    marketing campaigns won community

    banks new customers and profits.

    BY ALAN LENHOFF

    Planning PowerDont yawn: Strategic planning can positionyour community bank for profitability and

    productivity. Five ICBA members explain how.

    BY ELLEN RYAN

    COLUMNS

    From the TopRegulatory relief and lower premiums

    will help us help small businesses.

    BY R. MICHAEL S. MENZIES SR.

    Fine PointsGet ready for a busy legislative

    congressional agenda this fall.

    BY CAMDEN R. FINE

    Washington WatchThe trouble with the Consumer Financial

    Protection Agency as currently proposed.

    BY JASON KR ATOVIL

    Lender LifeHow changes to Regulation Z will

    affect your mortgage-loan process.

    BY BILL ELLIOTT

    Portfolio ManagementWhy mortgages can be an attractive

    institutional investment right now.

    BY JIM REBER

    Vantage PointBest practices for optimizing

    your banks efficiency ratio.

    BY KEVIN TWEDDLE

    WITH INTEREST

    NewslinesOn Capitol Hill, ICBA testifies on

    taxes and the financial overhaul.

    Tech TalkHow some banks are using Twitter.

    BY SCOTT MILLS

    Plus Tool Shop:Checking-account

    rewards, quick demographic reports,

    automated CD receipts and help

    with SBA construction-loan oversight.

    DEPARTMENTS

    Advertiser Index

    15 Minutes With Idaho community banker John Evans talks

    about working with family and motivating staff.

    55

    56

    35

    47

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    travelers.com2009 The Travelers Companies, Inc. All rights reserved. The Travelers Indemnity Company and its property casualty affiliates. One Tower Square, Hartford, CT 06183

    If only the wrong coverage were this obvious.

    To a Travelers agent, too much or too little insurance protection is just as obvious.

    Its an expertise weve gained by providing powerful, customized coverage to the

    Community Banking industry for over 100 years. And only Travelers SelectOne

    offers an unparalleled product mix of property, casualty, and specialty lines of

    insurance. Because coverage thats not perfectly tailored to your bank is bound to

    leave you feeling a little, well, exposed. To learn more, contact a Travelers agent.

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    http://www.travelers.com/http://www.travelers.com/
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    ICBA onlineV I S I T I C B A . O R G F O R T H E L A T E S T N E W S A N D A D V O C A C Y

    R E S O U R C E S A S C O N G R E S S D E B A T E S P O L I C Y S T E P S T O T A K E

    T O E N A C T F I N A N C I A L R E G U L A T O R Y R E F O R M .

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    _____

    One Mission. Community Banks.

    Each year, ICBA recognizes community

    banks for performing extraordinary acts of

    kindnessrepairing homes, serving meals,

    sponsoring local fundraisers, revitalizing

    Main Street.

    Now, its your turn to be recognized.

    Nominate your banks community service

    program for the 2010 ICBA National

    Community Bank Service Awards.

    Visitwww.icba.org/goto/awardsto

    download the 2010 National CommunityBank Service Awards nomination form.

    Nominations are due on December 4, 2009.

    The community

    youserve

    CONSUMER INFORMATIONVIDEOS FOR YOUTUBEICBA released three Money 101 videos on YouTube

    for consumers that promote the trusted financial

    expertise and service that community banks provide.

    The videos, prepared to reach consumers researching

    financial topics online, take a lighthearted approach to

    information on buying a home, saving for the future and

    building a relationship with a local community banker.

    ICBA encourages community bankers and their staff

    to share the videos online. Check them out at icba.org/

    youtube.

    CONSUMER SCAM RELEASEICBA produced another consumer news release

    offering tips to guard against loan scams. The release,

    Keep Your Personal Information Secure, outlines 10

    warning signs of fraudulent solicitations purporting to

    assist borrowers facing foreclosure or financial trouble.

    Community banks can tailor the release for distribution

    in their marketplaces.

    Find the release in the Consumer Education &

    Resources section.

    ICBA REDESIGNS HOME PAGEICBA recently completed the first phase in a Web-site

    redesign. The ICBA home page was reorganized to help

    community bankers more easily find the information they

    need. The site also offers an improved site search engine

    and landing pages. Look for more changes to come.

    _________

    http://www.icba.org/http://www.icba.org/http://www.icba.org/http://www.icba.org/youtubehttp://www.icba.org/goto/awardshttp://www.icba.org/goto/awardshttp://www.icba.org/youtubehttp://www.icba.org/youtubehttp://www.icba.org/http://www.icba.org/http://www.icba.org/youtubehttp://www.icba.org/goto/awardshttp://www.icba.org/youtube
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    www.icba.org ICBA IndependentBanker 5LENDER

    EQUAL HOUSING

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    ________________

    ________________

    mailto:[email protected]://www.msiloans.biz/http://www.msiloans.biz/mailto:[email protected]
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    ________________________

    http://www.metavante.com/http://www.metavante.com/http://www.metavante.com/
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    Young & Associates, Inc.Consultants to the Financial Industry

    Strategic Planning

    Regulatory Assistance

    Stock Valuations

    Capital Markets

    Expansion &

    De Novo Bank Charters

    Internal Audit

    Information Technology

    Recruitment &

    Human Resources

    Lending &

    Loan Review Services

    Compliance

    Policy Development

    ICBA HEADQUARTERS/EDITORIAL OFFICE

    1615 L St. NW Suite 900Washington, DC 20036-5623

    No. 09VOL.5

    9

    CUSTOM PUBLISHING

    GLC Custom Publishing900 Skokie Boulevard,Suite 200Northbrook, IL 60062(800) 641-3912

    P R E S I D E N T A N D C E O

    John Cimba

    V I C E P R E S I D E N T O F

    P R O J E C T M A N A G E M E N T

    A N D P L A N N I N G

    Rob Davis

    MAGAZINE STAFF

    S E N I O R V I C E P R E S I D E N T/C O M M U N I C A T I O N S

    Karen Tyson

    V I C E P R E S I D E N T/ P U B L I C A T I O N STimothy Cook

    A S S O C I A T E D I R E C T O R/ P U B L I C A T I O N SEllen Ryan

    A S S I S T A N T D I R E C T O R/P U B L I C A T I O N SThomas Warren

    C O M M U N I C A T I O N S C O O R D I N A T O R

    Michele Matthews

    A C C O U N T I N G C O O R D I N A T OR

    Kim Schneider

    D A T A C O O R D I N A TO RCindy Meyer

    S U B S C R I P T I O NS C O O R D I N A T OR

    Diane Meyer

    M A N A G I N G E D I T O R

    Alan Lenhoff

    A R T D I R E C T O R

    Olivia Roszkowska

    D I R E C T O R O F P R O D U C T I O N

    Monty George

    A D I N S E R T I O N C O O R D I N A T O R

    Tracy Cimba

    ICBA EXECUTIVE COMMITTEE

    C H A I R M A N

    R. Michael S. Menzies Sr.

    C H A I R M A N - E L E C TJames D. MacPhee

    V I C E C H A I R M A N

    Salvatore Marranca

    S E C R E T A R Y

    Wayne A. Cottle

    T R E A S U R E R

    Larry W. Winum

    P R E S I D E N T A N D C E O

    Camden R. Fine

    D I R E C T O R A T - L A R G E

    Jack E. Hopkins

    D I R E C T O R A T - L A R G ECharles F. Harper

    I M M E D I A T E P A S T

    C H A I R M A N

    Cynthia A. Blankenship

    P A S T C H A I R M A N

    Terry J. Jorde

    P A S T C H A I R M A N

    David E. Hayes

    C O R P O R A T E S E C R E T A R Y

    Mark A. Raitor

    ADVERTISING SALES

    James G. Elliott Co. Inc.626 Wilshire Blvd., Suite 500Los Angeles, CA 90017

    P R I N C I P A L

    James G. Elliott

    G E N E R A L M A N A G E R

    Dennis Connaughton

    N A T I O N A L A C C O U N T

    M A N A G E R

    Ted Hemminger(213) 624-0900, ext. [email protected]

    S A L E S D I R E C T O R

    Bob Washburn(213) 624-0900, ext. [email protected]

    (202) 659-8111(800) 422-8439E-mail:[email protected]

    icba.org

    Published by

    the Independent

    Community Bankers

    of America

    Periodicals postage paid at Sauk Centre, MN, and additional mailing offices.ICBA Independent Banker

    (SSN-0019-3674) is published by Independent Community Bankers of America, 518 Lincoln Road, Sauk

    Centre, MN 56378-1653. Member subscriptions, $40 per year. Additional member subscriptions, $20. All

    other subscriptions, $75. POSTMASTER: Address changes toICBA Independent Banker, P.O. Box 267, Sauk

    Centre, MN 56378. Copyright 2009 ICBA. All rights reserved.

    THE SPIRIT OF ENTREPRENEURIAL BANKING IN AMERICA

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    _________

    ______________

    ______________

    __________________

    mailto:[email protected]:[email protected]:[email protected]://www.icba.org/mailto:[email protected]:[email protected]:[email protected]://www.younginc.com/http://www.younginc.com/http://www.icba.org/mailto:[email protected]:[email protected]:[email protected]
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    __________________________

    http://www.phhcommunitybanker.com/http://www.phhcommunitybanker.com/http://www.phhcommunitybanker.com/
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    www.icba.org ICBA IndependentBanker 9

    ToP

    From the

    B Y R . M I C H A E L S . M E N Z I E S S R . , C H A I R M A N O F I C B A

    HELPING SMALL BUSINESSA good customer named Fran came into my com-

    munitybankthisweek.Hercompanysnatural-health

    products sell wonderfully, but she says she would be

    "going broke" if not for a loan from my community

    bank. Her loan is paying for inventory, employees,

    marketing and more.Smallbusinesseslikeherscreate

    95ofevery100new jobs.Just imaginehow fastwed

    getoutofthisrecessionifeveryFraninAmericacould

    borrowenoughcapitaland saveenoughassetstohire,

    buyand createtocapacity.

    Community banks use both flexibility and tools

    suchasSmallBusinessAdministrationprograms to

    solvesuchdilemmas.Ourcompetitiveadvantagelies

    incrafting creativesolutionsforeachcustomerwhile

    remaining prudentaboutriskand return.

    Februarys $787-billion Economic Recovery and

    Reinvestment Act contained several ICBA-backed

    tax-relief measures, including immediate $250,000expensing,thefirst-timehomebuyertaxcredit,alter-

    native minimum tax relief and municipal-bond ini-

    tiatives. But the country needs more. You and I

    know thatsmallbusinesses likeFranscan turn this

    economyaround,buttheycantdoitwithoutmoreof

    aboost.Thatboostwillcomefrom uscommunity

    bankersand from Congressand theWhiteHouse.

    Howcan Washingtonhelpsmallbusinessesgrow

    and thrive? For most, taxes are the second-biggest

    budget bite after labor costs. So lets urge improve-

    mentslikethese:

    taxreliefforsmallbusinesses,whichemployhalfofprivate-sectorworkers,

    abroad five-yearnetoperating losscarryback,

    a homebuyer tax credit raised to $15,000 and

    extended through2010,

    increased SBAprogram lending,and

    preferred stock flexibility and IRA shareholder

    investments for Subchapter S corporations to help

    businessesraisecapital.

    Thats how small businesses like Frans can save

    money.Theyalsoneed toborrowmoney,ofcourse,

    and for that they come to uscommunity banks.

    After all, we make half of all small-business loans

    under$100,000.Butweresmallbusinesses,too,and

    weneed helptohelpothers.

    Some of that help would

    come from H.R. 2897, the

    Bank Accountability and Risk

    AssessmentActof2009,sponsored

    by Rep. LuisV. Gutierrez (D-Ill.).

    This bill would broaden the

    assessmentbaseforFDICdeposit

    insurancesothatsome8,000com-

    munity banks would pay lower

    premiums.TheregularFDICpre-

    mium is still based on domestic

    deposits.Wed havemoremoney

    tolend ifthepremium werebased

    onassetslessTier1capital,asthe

    billcallsfor.

    H.R. 2897 would also create a

    systemic-risk premium for too-

    big-to-fail institutions, makingthem more accountable to the

    FDIC and taxpayers. Lets sup-

    port this legislation that would

    make the behemoths pay their

    fair shareor closer to itand

    takesomeresponsibilityfortheir

    effect on the economy and citi-

    zens wallets. If your representa-

    tive isntacosponsor,askhim or

    hertobecomeoneand makethis

    billintolaw.

    Tax relief for small businesses,regulatory relief for community

    banks, freed-up capital to lend for

    jobretention,economicgrowthand

    prosperitythatswhatwillgetour

    economybackon track.Letswork

    togethertomakethem happen.

    R. Michael S. Menzies Sr.is ICBA

    chairmanandpresidentandCEO

    of EastonBankandrustCo. in

    Easton, Md.

    Tax relief forsmall businesses,regulatory relief

    for communitybanks, freed-upcapital to lend

    for job retention,economic growthand prosperity

    thats what willget our economy

    back on track.

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    you now morethan ever.

    Your communityneeds

    With so many mega banks facing economic crisis, consumers are desperately looking for

    stability, a safe place for their money and a neighbor they can trust. As a cornerstone of

    your community, you have a unique opportunity to provide the security they seek.

    In turn, ICBA Services Network provides a full suite of offerings designed to keep you

    stable, solvent and prosperous: investment products, credit and payment services, lendingsolutions and insurance programs. Like you, weve been around a long time and well be

    here when you need us.

    ICBA Bancard & TCM Bank

    ICBA Securities

    ICBA MortgageICBA Financial Services

    ICBA Reinsurance

    One Mission.Community Banks.

    1-866-THE-ICBA

    www.icba.org/servicesnetwork

    Galen PeltonGrant County Bank, Ulysses, KS

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    www.icba.org ICBA IndependentBanker 11

    AUTUMN FOR TOO-BIG-TO-FAIL?

    Camden R. Fineispresident

    andCEO of ICBA. Reach him at

    [email protected].

    Aftera long Augustofscorching town-hallmeet-

    ingsintheirhomedistricts,membersofCongressare

    returning thismonthtothehighlyuncertainpolitical

    climate of Washington, D.C. This years remaining

    agendaforCongressand theObamaadministration,

    ambitious and wide-ranging, includes substantial

    issuessuchashealthcare,cap-and-trade legislation,

    anenergybilland the2010federalbudget.Enacting

    financialregulatoryreform thataddressesthedangers

    from too-big-to-failinstitutionsisalsoatoppriority

    ofboththeadministrationand theCongress.

    The administrations sweeping regulatory reform

    plan,thesubjectofcongressionalhearingsthatICBA

    participated in this summer, represents the most

    far-reaching financial legislation in 75 years. At its

    heart, the plan endorses many vital ICBA policy

    recommendations to rein in the megabanks and

    unregulated nonbanksthathavebroughtAmericans

    somuchanxietyand painduring thepasttwoyears.Communitybankersshould becautiousand vigi-

    lant but also confident and hopeful that our posi-

    tionsonhowtodealwithtoo-big-to-failwillhavean

    impactonthenationaldebate.Thepoliticalcredibil-

    ity and influence of community bankers and ICBA

    havenever beengreater in thenationscapital.True

    to ICBAs messages, community banks are widely

    regarded astrusted,common-sensefinancialprovid-

    ersthatneverwavered from serving and safeguarding

    theircustomerslong-term interests.

    As a result, theoutlook for community bankings

    policyobjectivesinWashingtoninstarkcontrasttoWallStreetsisbright.MostofICBAsmajorpolicy

    recommendations have had powerful allies in the

    administration and Congress from the outset. The

    administrations reform plan, which has some trou-

    bling and seriousflaws,incorporatesmostofICBAs

    keypolicyrecommendations.(Seethecoverstoryon

    page22and WashingtonWatchonpage12.)

    But, ofcourse, its the finaldetails thatmatter. In

    particular, how the statutory provisions are written

    and fitted together will determine how well they

    address too-big-to-fail. Itsstillearly inthe lawmak-

    ing process.Many legislatorsarestill learning about

    this issue and forming opinions about broad policy

    objectivesaswellasspecificmeasures.

    As with any legislation, how

    quickly the financial reform

    policymaking wheels will turn

    in Congress is uncertain. Its too

    soon to know if lawmakers can

    complete such a complex pack-

    age of financial reforms this year.

    Legislationcould moveforward in

    a piecemeal fashion with a series

    oftargeted billsthisyearand next.

    However, Americans are paying

    closeattentionto thisdebate,and

    lawmakersknowit.Americantax-

    payers know that too-big-to-fail

    wasamajorfactorinthefinancial

    crisis and severely complicated

    the governments efforts to fix it.

    Taxpayers know intuitively that

    until too-big-to-fail is resolved,theirmoneyisatrisk.

    After25yearsofwarning poli-

    cymakers about the dangers of

    too-big-to-fail,communitybank-

    ersand ICBAhaveagoldenoppor-

    tunitytoensurethatWashington

    fixes itproperly.Soplease follow

    thedebateonCapitolHillclosely

    this fall with your staff and col-

    leagues. Look for alerts from

    ICBA and be ready to respond,

    both in support of constructiveproposals and in opposition to

    harmfulones.

    The momentum to solve too-

    big-to-failisours.Whetherfinan-

    cial reform happens this year or

    next,letsgetthejobdoneright!

    Fine

    B Y C A M D E N R . FI N E , P R E S I D E N T A N D C E O O F I C B APoints

    Taxpayers knowintuitively that

    until too-big-to-failis resolved, theirmoney is at risk.

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    _________

    http://www.icba.org/mailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]://www.icba.org/
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    ecause much ink has been sponsides of the political spectrumdetermine Obamas eco ic idoly,e can begin to get a sense o

    wcommunity banking could befected by his adistrtion. The ecomic reforms Obama prposed n

    h e campaign trailn d his work in theS. Seate, XCFX-

    ecause much ink has been sponsides of the political spectrumdetermine Obamas eco ic idoly,e can begin to get a sense owcommunity banking could befected by his adistrtion. The eco

    mic reforms Obama prposed one campaign trail and his work ine U.S. Seate, icling involvementthe oments economic oncen

    AsPresident Obamas proposalsfor the sweeping financialregulatory reform package move

    this fall from recommendations

    to draft legislation, several crucial

    ICBA policy measures, including

    some that would begin to addresssystemic risks posed by too-big-to-

    fail institutions, are making signi-

    ficant headway. But more changes

    areneeded tothehistoriclegislative

    package, including additional too-

    big-to-fail measures that ICBA is

    recommending. (Read this months

    coverstory.)

    One partof the administrations

    regulatory reform package, to

    create the new Consumer Finan-

    cial Protection Agency (CFPA), isperhapsitsmostdangerouselement.

    ICBAand ourmembersaresparing

    no efforts to educate legislators

    about the potential problems for

    consumersand thefinancialsystem

    suchanextremelypowerfulagency,

    initsproposed form,could create.

    ensuring that standard consumer

    financial product or service, or

    so-called plain-vanilla products,

    are available to consumers.

    ICBA agrees with policymakers

    that existing regulatory gaps in

    regulating nonbanks and WallStreet firms need to be closed.

    However,communitybankershave

    alwaysoffered theircustomersthe

    safestand mostsound productsand

    services.ICBAhasbeenvigorously

    explaining why the CFPA, as

    proposed, is a classic example of

    a well-intended idea that would

    likelyresultinharm forconsumers

    and the already highly regulated

    community banks serving them

    honestlyand well.By separating consumer policy

    from safety-and-soundness super-

    vision of community banks by

    existing regulators, the CFPA

    would create more regulatory

    confusion without improving

    consumer protections. Increased

    regulatorycostsand potentialnew

    legal liabilities would be borne by

    all consumers, with the conse-

    quence of making many financial

    produc ts and services more

    expensive for all Americans and,

    possibly,unaffordableforsome.

    As first envisioned by the

    administration, the agency would

    have regulatory power over any

    firm directlyorindirectlyproviding

    awidearrayofconsumerfinancial

    products and services. The agency

    would have sole responsibilityfor examining and enforcing all

    consumer financial protection

    functions. The proposed agencys

    reach would extend far beyond

    mortgagesand real-estatefinancing,

    including consumerloans,payment

    cards, overdraft protection, credit

    insurance and investment and

    advisory services. It would have

    the power to interpret and update

    regulations for existing consumer

    financial-services laws,from TruthinLending toRESPAtoconsumer

    privacy to HOEPA and Truth in

    Savings. Itcould establishruleson

    compensation.And itcould impose

    cease-and-desist orders and huge

    finesand penalties.

    ICBA has expressed concern to

    the administration and Congress

    about imposing a one-size-fits-all

    regulatory approach to address

    problems created by nonbank

    financialproviders.Acorefunction

    oftheagencywould betopromote

    simplicityoffinancialproductsby

    The Consumer FinancialProtection Agency wouldcreate more regulatory

    confusion without improvingconsumer protections.

    ASCURRENTLYPROPOSED,THECONSUMER FINANCIALPROTECTIONAGENCYWOULDHARMCONSUMERSANDTHEFINANCIAL SYSTEMINMYRIADWAYS.ICBAANDCOMMUNITYBANKERSARELEADING THEEFFORTTO

    ENSURETHEBESTPUBLICPOLICYWINSOUT.

    ConsumerAgency Angst

    w a s h i n g t o n

    BY JASONKRATOVIL

    Jason Kratovilis ICBAvice

    presidentof

    congressionalpolicy.

    Reach him atjason.

    [email protected] .

    12 ICBA IndependentBanker September 2009

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    ___

    ___

    mailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]
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    http://www.sandleroneill.com/http://www.sandleroneill.com/
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    Rock Solid Financial Analytics

    Like too-big-to-fail financial firmswielding excessive power in themarketplace, the agency wouldhave too much concentratedregulatory authority.

    ICBA has made great strides

    in educating lawmakers to agree

    thatcommunitybanksworkwith

    their customers to ensure that

    they are well informed about

    the products and services they

    choose and that they are capable

    ofmanaging them.CFPA would,

    in effect, penalize community

    banksand theircustomersforthe

    deceptivepracticesofothers.And

    liketoo-big-to-failfinancialfirms

    wielding excessive power in the

    marketplace, the agency would

    have too much concentrated

    regulatoryauthority.

    Instead, ICBA has promoted

    a more targeted and balanced

    approach. The association

    has strongly advocated that

    supervision and enforcement

    of consumer protections forcommunity banks stay with

    existing regulators and that the

    CFPA and existing banking

    regulatorsjointlyhandleallother

    consumer-protection rulemaking.

    Thiswould eliminatetheneed for

    an appeals process to adjudicate

    possible conflicts between a

    banks primary regulator and the

    agency.

    In July, ICBA Chairman Mike

    Menzies,echoing FederalReserve

    Chairman Ben Bernanke, ex-

    plained to the House Committee

    on Financial Services the serious

    problems that would arise by

    splitting safety-and-soundness

    and consumer-protection regula-

    tory functions. Menzies empha-

    sized that consumer protections

    should focusonbringing unregu-

    lated nonbankentitiesinlinewith

    thestandard ofcommunitybanks.

    For example, the association

    advocates that lawmakers not

    requirefinancial-serviceproviders

    to provide the basic plain-vanilla

    financial products that commu-

    nity banks provide, but simply

    require nonbank financial-

    services providers to inform

    consumers that those products

    areavailableinthemarketplace.

    ICBA and its members have

    conveyed these concerns and

    recommendationstotheirrepre-

    sentatives before and during the

    August congressional recess.

    Hous e Fin an ci al S ervi ce s

    Committee Chairman Barney

    Frank (D-Mass.) said the CFPA

    would not target community

    banksastheadministrationfirst

    proposed. However, lawmakers

    will be working out the details

    ofthenewagencythisfall.

    Makeyourpositionknownontheproposed

    ConsumerFinancialProtectionAgency

    and otherregulatoryreform issuestoyour

    representativesinWashington.Pleaseencourage

    yourstaffand board memberstobecome

    involved aswell.

    Forasampleletteropposing theCFPAand forotherinformationontheproposed

    agency,visitICBAsGrassrootsAdvocacyCenter

    at icba.org.ClickonRegulatoryRestructuring

    onthehomepage,and scrolldowntofind a

    linktoadownloadableLettertoCongress:

    RegulatoryRestructuring: Enhancing Consumer

    FinancialProductsRegulation.

    w a s h i n g t o n

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    ________________________________

    http://www.fimacsolutions.com/http://www.icba.org/http://www.icba.org/http://www.icba.org/http://www.icba.org/http://www.icba.org/http://www.icba.org/http://www.fimacsolutions.com/http://www.fimacsolutions.com/http://www.icba.org/
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    www.icba.org ICBA IndependentBanker 15

    N e w s l i n e s

    T e c h T a l k

    with

    16

    18

    20

    ICBA Chairman Mike Menzies to Congress: Our economy ... needs a realcop on the beatplus small-business tax relief.

    How banks are using Twitter for public communications.

    Interest

    A checking-rewards program, demographic reports and automatedsafekeeping receipts.

    T o o l S h o p

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    http://www.icba.org/http://www.icba.org/
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    16 ICBA IndependentBanker September 2009

    Interestwith

    Taking measures to reduce systemic risk andeliminating too-big-to-fail is the best way toprotect consumers. Our economy needsmore than an early warning about possible

    problems; it needs a real cop on the beat.

    M M , I C B A

    More Tax Relief Needed,

    ICBA Tells Congress

    ICBA Chairman Mike Menzies

    urged Congress to craft a finan-

    cial-services regulatory reform

    program withmore safeguards

    such as procedures to downsize

    too-big-to-fail institutions in

    an orderly wayto reduce the

    risksof overconcentration toour

    nationsfinancialsystem.

    While praising the Obama

    administrations support in its

    draft program for ICBAs idea

    Because the weakened economyneedsmorehelp,ICBAurged law-

    makerstocomplementaggressive

    monetary easing by the Federal

    ReserveBoard byenacting avari-

    ety of small-business tax-relief

    measures. Testifying before the

    HouseSmallBusinessCommittee,

    Paul Merski, ICBA senior vice

    president and chief economist,

    outlined severalnewpolicymea-

    sures that would expand on the

    ICBAtax-reliefrecommendations

    included in FebruarysEconomic

    Recovery and Reinvestment Act.

    O N THE H ILL

    For details,seeICBAs

    fulltestimonyon icba.org.

    for additional supervisory costs

    and complications.

    Menzies also outlined ICBAs

    objections to the Consumer

    Financial Protection Agency

    as currently proposed to target

    less-regulated nonbank financial

    entities that betrayed the trust of

    theircustomers.Rulewriting and

    supervisionforcommunitybanks

    should remainwithexisting bank-

    ing agencies that coordinate both

    safetyand soundnessreviewsand

    consumer-protection enforce-

    ment,hesaid: Clearlyafinancial

    institutionthatdoesnotadhereto

    consumerprotectionrulesalsohas

    asafetyand soundnessproblem.

    For more on this topic,seetheFrom theTopcolumnonpage9,or

    read ICBAsJuly15testimonyonlinetitled, Economic Recovery: TaxStimulus Items that Benefited Small Business with a Look Ahead.

    ICBA Urges Improvements tothe Regulatory Overhaul Plan

    of imposing higher capital and

    liquidity requirements on too-

    big-to-fail institutions, Menzies

    explained totheHouseFinancial

    Services Committee the need to

    establish a separate systemic-risk

    reserve fund to resolve overly

    large banks and nonbank finan-

    cial firms. Also, he said, addi-

    tional fees should beassessed on

    any insured bank affiliated with

    a systemic-risk institution to pay

    O N THE H ILL

    Those new measures include

    expanding the net operating loss

    carryback to five years or more,

    boosting the first-time home-

    buyertaxcreditand allowing IRSshareholderinvestmentsand pre-

    ferred stock issuesbySubchapter

    Scorporations.

    Merski added that unduly bur-

    densomeand overlyaggressivebank

    exams and onerous new regula-

    tionsoncommunitybanksmustbe

    avoided to support small business

    lending and economicstrength.

    Rep.Nydia

    Velazquez and

    ICBAsPaulMerski

    N e w s l i n e s

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    http://www.icba.org/http://www.icba.org/http://www.icba.org/
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    _________________________

    http://www.harlandfinancialsolutions.com/http://www.harlandfinancialsolutions.com/http://www.harlandfinancialsolutions.com/
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    18 ICBA IndependentBanker September 2009

    ?BynowyouknowthatTwitteristhehotnewpubliccom-municationmedium whereusers,

    bothindividualsand organiza-

    tions,postmessages(ortweets)

    with140orfewercharacters.

    Financialinstitutionsofallsizes

    arecreating Twitteraccountsto

    communicatewithcustomers

    and thepublic.Theadoptionofthisplatform mayprovetobe

    thefastestofanytechnologyor

    communicationtoolinbanking.

    Asonemightexpect,theuse

    ofTwitteraccountsbycommu-

    nitybanksvariestremendously,

    asoutlined inTheBanking

    Twittersphere,areportpub-

    lished inMaybytheWilliam

    MillsAgency,whichexamined

    1,176 tweetsbymorethan60

    financialinstitutionsovera30-dayperiod.

    Thesurveyrevealed thatcom-

    munitybanksand creditunions,

    inparticular,tend tobeahead

    ofthecurveinusing Twitter

    Interestwith

    BY SCOTT MILLS tosharenewsand information.

    Institutionsareshowing Twitter

    personas,orstyles,inhowthey

    communicate,and thereare

    marked differencesinaverage

    numberoftweetsgenerated by

    big banks,regionalbanksand

    communitybanks.

    Followerscanbecustomers,

    potentialcustomers,vendorsand

    others.Somefinancialinstitu-

    tionsuseTwitterasawaytorecruitnewmembersbysharing

    newaccountpromotionsand

    rates,whileothersuseittoretain

    customersbysharing financial

    tipsorcommunitynews.Some

    organizationsdiscussbestprac-

    ticesamong theirpeers.

    Hereareseveralwayscommu-

    nitybanksareusing Twitter:

    Largebanksposted anaverage

    of53 tweetspermonth,fol-

    lowed bycreditunionswith22.5and communitybanks

    with8.4.

    Themostcommontweetby

    communitybankswasareply

    toatweetfrom someoneelse.

    Othertypesoftweetsbycom-

    munitybanksincluded these:

    links to Web addresses

    (24.7percent),

    corporation news,such

    asearningsstatementsor

    hirings(8.1percent),

    chatter,suchascomments

    ontheweatherorgeneral

    greetings(6.5percent),product promotions

    (2.7percent),

    industry news,suchas

    commentsontherecession,

    regulationsorpersonal-

    financeissues(2.1percent)

    and

    vendor discussions,such

    asupdatesonnewtechnol-

    ogy(0.1percent).

    Anexampleofacommu-

    nitybankusing Twitteris

    NorthAdams,Mass.-based

    MountainOneFinancialPartners,

    aholding companywithfour

    communitybanks.Liz

    Bissell,vicepresident,says

    MountainOnehasfourTwitter

    personastyles.

    Bisselladvocatescreating an

    editorialcalendarforsending

    tweetsregularly,establishing

    aformalbankpolicyonusing

    Twitterand educating employ-

    eesonuseand thebanksgoals.Bissellsayshercompanyspolicy

    includesactivitiesrelated to

    Facebookand LinkedIn.

    Asonepublicrelationsand

    communicationstoolofmany,

    Twitterwilllikelygrowin

    importancetocommunitybanks.

    Touseitmosteffectively,com-

    munitybanksshould promote

    theirTwitteraddressacrossall

    appropriatecustomertouch

    points,including theirWebsite,ads,branchesand employee

    e-mailsignatures.

    BecauseTwitterisanopen

    platform,anyonecanfollowyour

    communitybank.Oncebegun,

    theserviceshould beregularly

    used and monitored.Bissellsays

    MountainOnesmarketing team

    typicallyspendsabout30min-

    utesadaymanaging Twitter.

    Internalresourcesconcern

    manycommunitybanks,as

    doesthelearning curveto

    usetheplatform effectively.

    e c h a l k

    Many community banks are adopting Twitter for public communication

    Do YouTweet

    more resourcesForacopyoftheMountainOne

    Bankpolicyoranemployee

    social-mediapolicy,contact

    [email protected].

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    ______________

    mailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]
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    However,numeroustoolscan

    maketheprocesseasier,includ-

    ing TweetDeck,TweetSheep,

    HootSuiteand ReTweetRank.

    Twitterprovidesanew

    opportunitytocommunicate

    withcustomersand prospects,

    AsurveybytheWilliam MillsAgencyfound sixtypes

    ofTwitterpersonasthatcommunitybanksadopt.

    Problem SolversUseTwitterforcustomerserviceand tointeractwithcustomers.

    example tweet:@BofA_help: @kittenfacedI workfor

    BankofAmerica,isthereanything I candotohelp? Did the

    transpost,oraretheypending?

    Community ActivistsPromotelocaleventsand

    philanthropic activities,send weatherforecastsand more.

    example tweet:@1stMarinerBankMakesuretomakeit

    totheSt.PatrickParadeinBaltimorethisSunday! Weare

    aproud supporter.

    InformersActasconsumeradvocatesorpersonal-

    financeadvisers.

    example tweet:@mycucommunityGoodbyetobusiness

    cards? Professionalssharetheircontactinfo& moreviaSMS

    http://www.contxts.com.

    CommunicatorsCharacterized byfrequentretweetsand replies.Thesebanksliketoengageindiscussionsor

    sayhellotofriends.

    example tweet:@tonicreditunionInteresting

    thermalblindsvs.heatersidea.Howdoesthatwork?

    Social ButterfliesHaveTwittermanagerswho

    usetheiraccountspersonally(moresothan

    corporately).

    example tweet:@scheckingSchecking wantstoknow

    ifyousawusinUnionSquarethispastweekend!

    SidelinersPostfiveorfewertweetsin30days.In

    general,thesebankshavereserved theirnameonTwitter

    and areusing itasaplaceholder.

    Texas Digitals VitalCASTis a state-of-

    the-art digital signage solution that will

    excite, inform and motivate your bank

    customers.

    Attention-grabbing, professional content

    can be created, changed as needed, and

    deployed in a matter of minutes to one or

    more LCD or plasma displays.

    Indoor and outdoor displays ensure

    you reach your customers regardless of

    service channel.

    Call us today for aNo-Risk Consultation

    to find out how you can increase cross-

    sell of your full line of banking products

    and customer satisfaction with VitalCAST

    digital signage.

    800.693.2628

    VitalCASTDigital SignageTurns your lobby and drive-thru signage

    into full-motion brochures that get results

    VitalCAST delivers multiple messages on one screen to keep your customers

    informed. New products and services, customer/employee recognition and even

    television can be displayed side by side on LCD or plasma displays to enhance your

    marketing efforts and motivate your customers while waiting in line.

    particularlyyoungerones.In

    somecases,communitybanksare

    interacting withasmanycustom-

    ersviaTwitterastheydoattheir

    branches.Asconsumercom-

    municationspreferencesevolve,

    Twittercould createnewwaysfor

    communitybankstomaintaintheir

    customerrelationships.

    Scott Millsispresidentof William Mills

    Agency, apublic relations andmarketing

    rm inAtlantathatserves thenancial

    industry. His witterhandleis @wmaScott.

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    __________

    _______________

    http://www.contxts.com/http://www.contxts.com/http://www.contxts.com/http://www.contxts.com/http://www.contxts.com/http://www.contxts.com/http://www.contxts.com/http://www.txdigital.com/mailto:[email protected]://www.txdigital.com/mailto:[email protected]:[email protected]://www.txdigital.com/http://www.contxts.com/
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    20 ICBA IndependentBanker September 2009

    Interestwith o o l S h o p

    Th e Ba ncVue premium-

    rewards progra m allows

    accountholders to tailor how

    they receive loyalty rewards.

    Accountholders, for example,

    can receive rewards in an

    automatic savings account, as

    iTunes downloads or as funds

    directed to charities.

    AP P L E AD V E R ISIN G

    Fast Demographic Reports

    SB A O N E S O U RCE

    SBA Construction Loan

    SBA OneSource in Denver

    is offering a new construc-

    t io n l ending service man -

    agemen t fo r Small Business

    Administration7(a) loans.The

    outsourceservicehelpslenders

    cost-effectively oversee con-

    struction projects that receiveFor details: sbaonesource.com.

    B ANCV U E L D.

    Checking Rewards Program Branding

    BancVue Ltd. , an ICB A

    Preferred Service Provider

    for premium-rewards check-

    ing,is launching anationwide

    brandin g an d adve rti si ng

    ca mpa ign. Th e brand name

    Kasasa identifies BancVues

    account-rewards progra m ,

    wh ic h a ll ows c omm unity

    b an ks t o generate deposit

    growthand encourageaccount

    ho lders to use cost-efficient

    paymentoptions.

    BancVuesupportsthe Kasasa

    brand wi th l oc al advert is -

    ing campaigns for participat-

    ing banks. Company officials

    say a limited number of banks

    will have their names associ-

    ate d with the Kasasa brand-

    ing and advertisi ng campaigns

    launched inAugust.For more:kasasa.com/learn.

    Automated Safe-keeping Receipt forNonbrokered CDs

    Q WI CK RA E

    For more:qwickrate.com.

    QwickRate, ICBAs Preferred

    Service Provider for non-

    brokered CDs, introduced a

    feature that automates safe-

    keeping receipts fo r issuersand investors. The feature,

    called Safekeeping Receipt,

    frees institutions fro m relying

    on paper and postage receipt

    docu ments, further eliminat-

    ing time and cost fro m direct

    CD transactions. The ICBA-

    QwickRate pro gram provides

    members with discounts on

    subscriptionsto the companys

    nationwide nonbrokered CD

    marketplace.

    Customized household and marketdemographicreportsareavail-

    able from Apple Adver tis ing in Asheville, N.C. Delivered within

    eight hours, eachreportcostslessthan$250 and can featurecensus

    data for single-county or multiple-county marketplaces and cur-

    rentdata orthree-yearprojected trends. Household data can cover

    income, age, debt and financial pro duct use. Other information

    includes data on number ofbranchesand aggregate deposits.

    INADDITIONTOUNMATCHEDSERVICEANDEXPERTISE,COMMUNITYBANKSOFFERAMONG THEBESTIFNOTTHEVERYBESTPRODUCTSANDWARESAVAILABLEINTHEFINANCIAL SERVICESINDUSTRY.THEYDOTHISTHROUGH ARANGEOFBUSINESSPARTNERSHIPSANDSPECIALIZEDOUTSOURCEDPROVIDERS.THISMONTHSTOOLSHOP HIGHLIGHTSCOMPANIESTHATCONTINUETOINNOVATEANDIMPROVETHEIRWARESFOR THEBENEFITOFCOMMUNITYBANKS.

    For information:appleadv.com/demostudy.

    SBA financing. T he s ervi ce

    helps evaluate the status of

    contractor license and insur-

    ancestatus, achievequickSBA

    l oan appro vals and handle

    compliance and cost reviews.

    Management Service

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    www.icba.org ICBA IndependentBanker 21

    2

    009,

    FannieMae.

    Registeredtra

    demarks.

    MakingHomeAffordableisatrademarkofth

    eUnitedStatesDepartmentoftheTreasuryandisused

    underlicense.

    w w w . e f a n n i e m a e . c o m

    Together...

    Making

    Home

    Affordable

    In communities across the country, Fannie Mae is committed to working with partners

    like you. As part of the Making Home AffordableSM

    Program, we offer community bankstools to support Home Affordable Refinance and Home Affordable Modification. With our

    Refi PlusTM options, you can help Fannie Mae borrowers refinance to reduce their monthly

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    www.efanniemae.comorwww.financialstability.gov.

    For further details on how the ICBA/Fannie Mae alliance can help you in todays challenging market,contact your customer account manager or Tammy Trefny at 312-368-6218 or tammy_ [email protected].

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    ________________________

    ___________________

    http://www.efanniemae.com/http://www.efanniemae.com/http://www.financialstability.gov/mailto:[email protected]:[email protected]://www.efanniemae.com/http://www.efanniemae.com/mailto:[email protected]://www.financialstability.gov/http://www.efanniemae.com/
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    TOO

    F I N A N C I A L R E G U L A T O R Y R E F O R M

    Financial regulatory reform leg-

    islation aiming to subdue sys-

    temically dangerous, sometimes

    predatory institutions is in the

    arms of Congress. This month

    congressional leaders, fresh

    from townhallmeetingsduring

    anAugustrecessand aftersev-

    eral summer hearings on the

    Obamaadministrationsblueprintforchange,plan

    to roll up their policymaking sleeves to fashion

    togetheraconsensusoveracatalog ofcomplexand

    potentially far-reaching proposals that could lead

    tofinallegislation.

    22 ICBA IndependentBanker September 2009

    THEERAOFTOOBIGTOFAILFINANCIALINSTITUTIONS,WHEREGIANT DINOSAUR BANKS AND NONBANKS WERE ALLOWEDTO FEAST AND GROW WITH ABANDON, COULD BE IN ECLIPSE.

    CONGRESS SETS OFF TO TAME THE DINO-BANKS

    By Steve Verdier

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    We should not be forced to choose between allowinga company to fall into a rapid and chaotic dissolution

    or supporting the company with taxpayer money.That is unacceptable. There is too much at stake.

    P B O J

    www.icba.org ICBA IndependentBanker 23

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    http://www.icba.org/http://www.icba.org/
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    ___________

    http://www.visa.com/payrollhttp://www.visa.com/payroll
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    Join the debate.Makeyourpositionon financialregulatory

    reform knowntoyourcongressionalrepresentatives inWashington,

    and encourageyourstaffand directorstogetinvolved aswell.

    To help the nations community bankers easily and effectively

    communicate with members of Congress, ICBA has developed a

    rangeofcustomizableletters,positionsummariesand background

    information on financial regulatory reform. Visit icba.org and

    click on the Regulatory Restructuring link under the Grassroots

    AdvocacyCenter.

    Resources to Contact Your Representatives

    inJune.Thestakesareveryhigh.The[publicpolicy]

    processpresentsbothopportunitiesand risks.Wehave

    anopportunitytoaddresstoo-big-to-failand finally

    free our financial and economic markets from its

    dangerousgrip.

    Sofar,congressionalcommitteesoverseeing finan-

    cial regulation have held public hearings with top

    Treasuryand banking agencyofficialsinresponseto

    thepresidentsplan.Thosehearings, inwhichICBA

    has participated, have aired variousviewpoints. A

    fewnarrowlytargeted billshavebeenintroduced anddebated.However,nospecificcomprehensivelegisla-

    tivepackagehasbeenintroduced inCongress,and a

    majorityoflawmakershavenottakendefinitiveposi-

    tionsonarangeofpolicyoptions,including thepiv-

    otalmeasurestheyllsupporttoend too-big-to-fail.

    In congressional testimony last October through

    thisJuly,ICBAhasoutlined coreprinciplestoguide

    policymakers on financial regulatory reform. Those

    principles includeaiming newregulatoryreformsat

    too-big-to-failbanksand nonbanks,supporting mul-

    tiple federalbanking agencies,maintaining thedual

    Nearly every pillar of our

    nations regulatory framework

    faces the potential for a substan-tial,evenaradicaloverhaul.New

    regulatory standards, authorities

    and governmentbodiesarebeing

    considered. Whatever final leg-

    islativepackage thatmay emerge

    from the Congress could, for

    better or worse, in large mea-

    sure determine how safely, resil-

    ientlyand effectivelyournations

    modernfinancialsystem recovers

    long term from thetoo-big-to-fail

    contagion that was the primary

    underlying cause of the financial

    marketscrisis.

    Lawmakers must consider a

    hostoftechnicallyand philosoph-

    ically complex policy questions

    covering new regulatory ground:

    What regulatory gaps must be

    closed? Howwillsystemicriskbe

    monitored and addressed? How

    should nonbank activities be

    regulated? How should financial

    consumers be better protected?

    Individual lawmakers and fed-eral banking agency chiefs have

    weighed in with a few different

    ideas, as ICBA has with specific

    core policy recommendations.

    For Main Street America and

    community banks, however, the

    success or failure of any final

    and inevitably huge financial

    regulatory reform package will

    be judged by how effectively it

    addressesor eliminates, as

    ICBA is working forthe ongo-ing systemic dangers created by

    immense and complex bank and

    nonbankcompanies.Ourcountry

    will likelylivewiththe legislative

    resultsforgenerationstocome.

    America now stands at a his-

    toric crossroads with financial

    regulatory reform, wrote ICBA

    Presidentand CEOCamdenFine

    in an open letter to the nations

    communitybanksaftertheObama

    administration introduced its

    financial regulatory reform plan

    READ MORE:

    ICBA Core

    Principles

    Financial

    Regulatory

    Reform

    on page 26

    www.icba.org ICBA IndependentBanker 25

    (continued onpage28)

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    http://www.icba.org/http://www.icba.org/http://www.icba.org/http://www.icba.org/http://www.icba.org/http://www.icba.org/http://www.icba.org/http://www.icba.org/
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    ICBA .

    SYSTEMIC RISK. Place systemic-risk insti-

    tutions under immediate prudential supervi-

    sion by a federal agency. Vest the FDIC with

    authority to resolve and unwind systemically

    dangerous institutions. Impose higher capital

    and strongerrisk-managementrequirementson

    too-big-to-failinstitutions.Eventually,downsize

    institutions that could jeopardize our entire

    financialsystem iftheyfailed.

    DUAL BANKING. Maintain the system of

    federal and state bank charters to promote

    a diversity of consumer choice and financial

    institutions.Having multiplecharteroptions

    both federal and stateis essential for main-

    taining an innovative and resilient regulatory

    system.

    REGULATORY DIVERSITY. Continue mul-

    tiplefederalbanking regulators.Having multiple

    federal agencies regulating depository institu-

    tions providesvaluable regulatory checks and

    balancesand promotesbest practicesbyallow-ing multipleviewpointsmuchlikehaving mul-

    tiplebranchesofgovernment.

    DEPOSIT INSURANCE ACCESS. Maintain

    FDIC deposit insurance for all federal and

    state chartered banks. Deposit insurance as an

    explicit government guarantee has been the

    stabilizing forceofournationsbanking system

    for75years.

    DEPOSIT INSURANCE ASSESSMENTS.

    Chargesystemic-riskinstitutionsadditional

    FDIC-insurance pre miums for the extra

    risks they pose to the Deposit Insurance

    Fund. Broaden the FDIC assessment base

    to include all assets of insured institutions

    minus their tangible equity. The amount of

    assets an institution holds more accurately

    gauges an institutions risk to the DIF than

    the amount of its deposits. Create a spe-

    cial reserve fund that remains adequately

    capitalized by systemically risky financial

    institutions.

    CONSUMER PROTECTION. Federal bank-

    ing regulators should continue both safety and

    soundness oversight and consumer-protection

    regulationforcommercialbanksand savingsinsti-

    tutions. Limit consumer-protection supervision

    by a proposed Consumer Financial Protection

    Agency to unregulated nonbank financial com-

    panies,and developoverallconsumerprotection

    rulesthrougharegulatorycoordinating commis-

    sionthatincludesfederalbanking agencies.

    DEPOSIT CONCENTRATION. Reduce or

    strengthenthe10-percentdepositconcentration

    cap.Thecurrenteconomiccrisishighlights the

    dangers of concentration of financial resources

    intoofewhands.

    THRIFTS. Because savings institutions play an

    essentialrole inproviding residentialmortgage

    credit in the United States, the thrift charter

    should not be eliminated, and the Office of

    Thrift Supervision should not be merged into

    theOfficeoftheComptrolleroftheCurrency.

    GSE FUNDING.Preservetheroleofthehousing

    government-sponsored enterprises. To provide

    safe and needed home loans to their custom-

    ers, many community banks rely on Fannie

    Mae,FreddieMacand theFederalHomeLoan

    Banks for liquidity and asset-liability manage-

    mentthroughtheadvancewindow.

    BANKINGAND COMMERCE.Closetheindus-trial loan company loophole to maintain the

    separation of banking and commerce. Mixing

    banking and commercehas a history of failure

    throughouttheworld and has led to inefficient

    economiesand prolonged and deeprecessions.

    NEW TREASURY OFFICE.EstablishanOffice

    ofCommunityFinancialInstitutionswithinthe

    TreasuryDepartment.Theoffice,whichshould

    be headed by an assistant Treasury secretary,

    would ensure that the unique needs and inter-

    estsofcommunitybanksarebeing considered.

    ICBA Core PrinciplesFinancial Regulatory Reform

    26 ICBA IndependentBanker September 2009

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    www.icba.org ICBA IndependentBanker 27

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    ________________

    http://www.icba.org/http://2009fiserv%2Cinc.oritsaf.liates/http://www.newfiserv.com/http://www.bankintelligence.fiserv.com/icbawebinarshttp://www.newfiserv.com/http://www.bankintelligence.fiserv.com/icbawebinarshttp://www.newfiserv.com/http://2009fiserv%2Cinc.oritsaf.liates/http://www.icba.org/
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    banking system and ensuring that

    thelargestinstitutionsadequately

    contribute to the FDICs risk-

    based assessments.

    Among those principles ofmost fundamental importance

    to community banks and Main

    Street America are ICBAs spe-

    cificrecommendationstoaddress

    systemic risks posed by too-

    big-to-fail banks and nonbank

    financial companies. As a result,

    the Obama administration and

    several key congressional leaders

    have publicly embraced many of

    ICBAs core policy priorities on

    regulatory reform, particularly

    thosedealing withtoo-big-to-fail.

    ICBA has received support from

    the administration and congres-

    sionalalliestocreateconsolidated

    systemic-risk supervision and

    imposehighercapitaland liquid-

    ity reserve requirements on too-

    big-to-failbanksand nonbanks.

    ICBAhasalsowontheadminis-

    trationsearlysupporttoestablisha segregated systemic-risk fund

    for nondepository institutions to

    coverresolutionexpensesaswell

    as a systemic-risk premium for

    large depository institutions to

    cover their risks to the Deposit

    Insurance Fund. As Treasury

    Secretary Timothy Geithner told

    the House Financial Services

    Committee, Right now in the

    currentsystem,itsfundamentally

    unfairbecausesmallerbanksare

    forced toabsorbadisproportion-

    ate cost of intervention needed

    toprotectthesystem from,often,mistakesmadeby

    largerinstitutions.

    Last month, the administration also endorsed an

    ICBApolicyprioritytocreateatwo-tiered feestruc-

    ture for regulatory examinations and complianceoversight that would reflect the systemic risk the

    largestbankspresent.Asmoreevidencethatcommu-

    nitybankersvoicesarebeing heard inWashington,

    the administration proposed that banks with over

    $10 billion in assets would see their regulatory

    fee increases under the current banking agencies

    and any proposed Consumer Financial Protection

    Agency.Bankswithunder$10billioninassetsunder

    the administrations proposal would pay less for the

    proportionally lower risk and regulatory costs they

    create.

    Additionally, the plan would require that fees

    assessed onnationalbankswithlessthan$10billion

    inassetscould notbehigherthantheaveragecharged

    bystatesforbanksofsimilarsize,whichwould lower

    the fees for many community banks. The Federal

    ReserveortheFDICwould havenobasistoimpose

    newfeesoncommunitybanksundertheproposal.

    TheproposaladoptstheICBAviewpointthatany

    firm that engages in risky activities, or becomes so

    large that its instability presents a risk to the entire

    financial system, should pay regulatory fees com-

    mensuratewiththeriskand regulatorycostsitposes.

    Clear evidence that community bankersvoices are

    being heard inWashington: MichaelS.Barr,assistantTreasurysecretaryforfinancialinstitutions,told the

    Washington Post: The largest institutions require

    greateroversightand intermsofconsumers,theyare

    reaching many, many more with more complicated

    products.

    Some of these ICBA policy recommendations

    are incorporated in legislation introduced in the

    House of Representatives and the Senate. Rep. Luis

    Gutierrez (D-Ill.), chairman of the House Financial

    ServicesSubcommitteeonFinancialInstitutionsand

    Consumer Credit, introduced a bill (H.R. 2897)

    that would broaden the assessment base forFDIC deposit insurance

    premiumsand create

    a separate risk-based

    assessment for federally

    insured too-big-to-fail banks.

    Sens.MarkWarner(D-Va.) and Bob

    Corker(R-Tenn.),bothSenateBanking

    Committee members, introduced a

    bill (S. 1540) that would give the

    FDIC the authority to resolve,

    or wind down, bank hold-

    ing companies. Rep. Dennis

    Cardoza(D-Calif.) introduced

    a bill (H.R. 2676) to create a

    America now stands at a historic crossroadswith financial regulatory reform. The

    stakes are very high. The process presentsboth opportunities and risks. We have anopportunity to address too-big-to-fail and

    finally free our financial and economicmarkets from its dangerous grip.

    I C B A P C E OC F , J

    28 ICBA IndependentBanker September 2009

    Read about

    ICBAs efforts

    on the pro-

    posed Consumer

    Financial

    Protection Agency

    in Washington

    Watch on

    page 12.

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    Our Difference is YouJust like in community banking, its the ownership that determines the nature of a company. Its the

    same way with your EFT network. SHAZAM is member-owned and member-driven. And like my

    bank. Why would I trust that to someone who is also a competitor? I need a business partner who

    is independently member-owned and -controlled. Thats why I chose SHAZAM.

    For more information about SHAZAM, visit us at www.shazam.netor call (800) 537-5427.

    Steve Handke

    President & CEO

    Union State BankEverest, Kansas

    Our electronicpayments are

    too important totrust to someonewho could be

    our competitor.

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    http://www.shazam.net/http://www.shazam.net/
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    30 ICBA IndependentBanker September 2009

    The community

    youserve

    One Mission. Community Banks.

    Each year, ICBA recognizes community

    banks for performing extraordinary acts of

    kindnessrepairing homes, serving meals,

    sponsoring local fundraisers, revitalizing

    Main Street.

    Now, its your turn to be recognized.

    Nominate your banks community service

    program for the 2010 ICBA National

    Community Bank Service Awards.

    Visitwww.icba.org/goto/awardsto

    download the 2010 National Community

    Bank Service Awards nomination form.

    Nominations are due on December 4, 2009.

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    new assistant Treasury secretary position to enhance

    thevoiceofournationscommunitybankswithinthe

    TreasuryDepartment.

    TheObamaadministrationand severalseniorlaw-

    makershavealsobacked ICBAsrecommendationto

    givetheFDICspecialresolutionauthoritytoresolve

    and unwind systemically dangerous financial firms.

    But some lawmakers, including House Financial

    Services Committee Chairman Barney Frank

    (D-Mass.), have questioned whether such authority

    and proceduresshould beaddressed inseparateleg-

    islation.ICBAcontinuestoadvocatethathaving clear

    authorityand proceduresinplace

    tounwind systemicallydangerous

    institutions is an essential regu-

    latory component of addressing

    too-big-to-fail in a cohesive andcomprehensiveway.

    In testimonybefore theHouse

    Financial Services Committee in

    July, ICBA Chairman R. Michael

    S. Menzies Sr. outlined critical

    ICBA recommendations tomake

    the administrations regulatory

    reform plan effective in address-

    ing the causes of the financial

    crisiswithoutcreating unintended

    problems for community banks

    and Main Street America. For

    example, ICBA recommends

    that lawmakers designate the

    Federal Reserve as the nations

    primary systemic-risk regulator

    and enhance the authority and

    dutiesofaproposed councilthat

    would overseetheFedssystemic-

    (continued onpage33)

    Even in the midst of this economic crisis, thenations community banks continue to help their

    customers and communities recover. Its vital thatCongress does its part by ending too-big-to-fail and

    reducing systemic risk in order to protect consumers,local communities, and our entire financial system

    from the destabilizing effects that occur when agiant institution runs into trouble.

    I C B A C R . M M , C I C B A , J

    http://www.icba.org/goto/awardshttp://www.icba.org/goto/awards
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    ____________

    http://www.strunklp.com/http://www.strunklp.com/
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    __________________

    _______________

    http://www.datacenterinc.com/http://www.datacenterinc.com/http://www.datacenterinc.com/http://www.datacenterinc.com/
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    www.icba.org ICBA IndependentBanker 33

    risk actions. The Financial Services Oversight Council

    proposed bytheadministrationshould alsoberesponsible

    foridentifying gapsinregulationand recommending which

    nonbankentitiesshould bebroughtundertheFedscon-

    solidated supervision.

    Tomaketoo-big-to-failregulationeffective,ICBAalso

    believes that Congress should require regulators to pub-

    licly identify systemically risky institutions. Congress

    should also establish clear principles to identify them,

    and ICBAhaspresented specificguidelines,whethersuch

    an institution be a bank or nonbank. Additionally, each

    large financial institution should develop an insolvency

    contingencyplanthataresolutionauthoritycould usein

    theeventofitsfailure.

    In addition to raising the capital, liquidity and risk-managementstandardsofthelargestfinancialinstitutions,

    however, ICBA also has made it clear to policymakers

    that downsizing systemic-risk institutions is an essential

    step. Financial holding company premiums and capital

    requirements should be increased, on a graduated basis,

    forinstitutions$100billioninassetsand largertoprotect

    againstthepotentiallyhugelossestheycould generateand

    todiscourage excessive growth. ICBA spelled out a five-

    year downsizing process for systemic-risk institutions,

    including measurestogivetheU.S.DepartmentofJustice

    antitrust-likepowersoverthelargestfinancialinstitutions.

    Anunwinding processshould allowcommunitybankstoacquirepiecesofdownsized institutions.

    As with any legislation, how quickly the policymak-

    ing wheels for financial regulatory reform will turn in

    Congress, particularly in the Senate, is uncertain. The

    Obama administration and some congressional leaders

    want to pursue the ambitious timetable of enacting a

    financialreform packagebyNewYears.Withtheterrible

    aftermathofthefinancialmarketscrisisand itslingering

    economicfallout,Congresshaspowerfulincentivetoact.

    For if policymakers had not allowed a few banks and

    nonbanks to swell unrestrained to monster proportions,

    thecrisisofthepastthreeyearswould neverhavepushed

    Americasfinancialsystem tothebrinkofcollapseasitdid.

    TheObamaadministrationagrees,asdomanymembers

    ofCongressand avastnumberof

    Americans. Continued pressure

    and vigilancefrom ICBAand the

    nations community banks could

    end too-big-to-fail.Thedaysofdino-bankscould be

    numbered.Ourcountryand Main

    StreetAmericawillbesaferwhen

    they become fossils of a wilder,

    moreperilousfinancialpast.

    Steve Verdieris seniorvicepresident

    anddirectorof congressional affairs.

    Reach him [email protected].

    Community bankers have spent the past25 years warning policymakers of the

    systemic risk presented by the unbridledgrowth of the nations largest banks and

    financial firms. Congress should requirethe financial agencies to identify, regulate,assess and eventually break up institutions

    posing a risk to our entire economy.

    C B A , C

    I C B A , M

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    ____________

    ________________

    _____________

    http://www.icba.org/mailto:[email protected]://www.holtandmon.com/mailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]://www.holtandmon.com/http://www.holtandmon.com/mailto:[email protected]:[email protected]://www.icba.org/
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    2009 Freddie Mac

    Freddie Mac provides the housing market with quick access

    to a constant source of liquidity. We are a stable source

    of mortgage financing in all markets, every day, including

    super conforming mortgages in high-cost markets. You can

    depend on Freddie Mac to provide liquidity for the affordable

    mortgage financing that you and your borrowers need. www.FreddieMac.com

    Today. Tomorrow. Together.SM

    Proud to play a leading role in theMaking Home Affordable Program.

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    http://www.freddiemac.com/http://www.freddiemac.com/
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    www.icba.org ICBA IndependentBanker 35

    OUT

    Gettin

    g theWo

    rd

    By Alan Lenhoff

    ICBA Independent BankerAdvertising All-Stars

    FOUR SAVVY COMMUNITY BANKS USE A VARIETY OF CREATIVE MARKETING

    IDEASAND MEDIATO CREATE TOP-NOTCH ADVERTISING CAMPAIGNS

    35

    Doing business with-

    outadvertising islike

    winking at someone

    inthedark.Youknowwhatyou

    aredoing,butnobodyelsedoes.

    Its not clear who said that

    first,butanybusinessthatoffers

    products or services, including

    community banks, can appreci-

    atethesentiment.

    ICBA Independent Banker

    chose four community bank

    advertising campaigns to spot-

    light for their creativity and

    effectiveness aspartofitsannual

    advertising showcase. Each cam-

    paign reflects different goals,

    philosophiesand creativity.One

    campaign is by a 157-year-old

    community bank; another bank

    was chartered in 2005. A third

    bank seeks a bigger foothold

    in mortgage lending; a fourth

    strives to solidify dominance in

    smallbusinesslending.

    Whatallfourcampaignshave

    incommon iscreativebutrigor-

    ous marketing strategies imple-

    mented through a variety of

    approaches. Every community

    bankisunique.SoiseveryMain

    Streetmarket.Noonemarketing

    strategyoradvertising campaign

    is universally applicable. But

    as these advertising campaigns

    show, creativity and dedication

    can help any community bank

    increase its impact and market

    share.

    OUT

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    36 ICBA IndependentBanker September 2009

    FIRST BANK FINANCIAL CENTRE

    O C O N O M O W O C , W I S .

    Located about 30 miles

    west of Milwaukee, Oco-

    nomowoc is a thriving

    town that predates the Civil War

    and has become an exurban bed-

    room community. There, First

    Bank Financial Centre began

    reaching out this past spring to

    servemoreconsumersinthegrow-

    ing nearbypopulationcenters.

    For many years, says Jodi

    Schwefel, First Bank Financials

    marketing director, we consid-

    ered ourselvesacommerciallend-

    ing bank.Buteconomictimesdo

    not now warrant a great deal of

    commercial loans.Toreposition

    and expand the$650million-asset

    community banks balance sheet,

    she says, First Bank Financial

    aimed to increase its residential

    mortgagelending.

    Schwefel and her colleagues

    created an advertising campaignthat addressed homebuyers

    through print, broadcast, online

    and in-branch outlets. The

    mixed-mediacampaignstroveto

    raiseawarenessamong customers

    and noncustomersthatFirstBank

    Financial offers home-mortgage

    loansand,asaresult,increasethe

    banksportfolioofthoseloans.

    Featuring the slogan Home

    LoanSale,thecampaignstressed

    thevalue ofdoing business witha community bankpersonal

    assistance and advice, free

    pre-approvals, fast loan deci-

    sions, people you know and

    trust. Schwefel also used a logo

    celebrating thebanks150thanni-

    versary to underline the themes

    of safety, soundness and relation-

    shipbanking.

    The campaign consisted of

    twoweeksofnewspaperadver-

    tising intwocountiesthatinclude

    much of suburban Milwaukee,

    atwo-weekradiocampaignon

    two major AM and FM stations

    intheMilwaukeearea,anad onFirstBankFinancials

    Web site that offered $100 off

    closing costs for consumers who

    applied online,

    a mass e-mail to First Bank

    Financialcustomerswhodid not

    have a mortgage loan with the

    bankand


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