by Amanda Martin, VP/Calling Officer The Independent Community Bankers Association (ICBA)’s Subsidiary, ICBA Payments, has teamed up with Pidgin to help make Instant Payments easier for community banks to tackle. The Bankers Bank also has a partnership with Pidgin and is excited about what this additional alliance will mean for customers.  As the world of FedNow continues to grow, many community banks seem to find themselves stuck in receive-only mode. Whether that is due to cost, core, or personal choice, the fact is that someone needs to send for others to receive.  Pidgin is a secure faster payments platform that can both send and receive instant payments. It has a central connection point to FedNow, as well as other faster payments networks such as RTP or Zelle, which allows community banks to deliver options to their customers. Pidgin works straight from the customer account, routing payments directly to and from financial institutions. That means that funds are kept with the bank, as opposed to being held in a virtual wallet with a fintech provider, which creates safer transactions and lower fees.  What does this mean for you? As a customer of The Bankers Bank, you have the option of using Pidgin! Pidgin integrates into most cores and allows customers to initiate payments through a banking app and/or online banking program. Pidgin processes the payments, settlement for entries comes from Fed, and Liquidity Management is a service TBB provides to monitor balances after hours, on weekends and holidays.  The Bankers Bank is excited about what the new partnership between Pidgin and ICBA will entail. Today’s fast-paced market requires community banks to be ultra-competitive, and this option can help us all navigate the payments landscape with more ease of mind.  If you have questions about Pidgin, FedNow or other payment options, please reach out to your calling officer. TBB is here to help!

by Kas Stewart, SVP & AAP ISO20022 has been implemented. This was so much more than a system upgrade, it is a fundamental change to how we all move money. Processes have changed, which means we all must make some adjustments, but soon this will become routine and comfortable.  NACHA will be adding five new rules in October 2025 through June of 2026 related to fraud risk. These apply to both originators, third party senders and receiving financial institutions at various dates during this timeframe. The first implementation is for ODFIs, Third Party Senders and Third Party Service Providers, and Originating Financial institutions with more than 10,000,000 items in 2023. The deadline for this is March 2026. The second phase of implementation is June 2026 and applies to all others.  You may want to review the risk management framework on the NACHA website as well as the rules. There is also a webinar presented by Debbie Barr that provides great detail. It will be up to each bank to decide how they will monitor and what solution they will use to carry out this process. NACHA is not expecting technical solutions, although that is an option. What they expect to see is risk-based processes and procedures. Suggestions include beginning the process now by reviewing your ACH risk assessment and then also performing a Gap analysis, establishing some parameters/red flags based on certain entry class codes or monitoring for anomalies in the value of items received by customers. And beyond deciding how you identify fraud, the steps you will take after the fraud is detected. They will expect to see documentation when you perform your annual ACH audit. There is no expectation that every transaction is checked. The monitoring does not have to be done prior to posting. Deciding that you have no risk and doing nothing is not acceptable.  On a separate note, NACHA has also recommended a best practice for ACH returns. Use Same Day ACH files for return entries that were not received as same day ACH.

by Steve McIlhaney, SVP , Director of Business Development Despite the many digital payment options and advancements, check fraud continues to surge throughout the US. Check fraud involves tens of thousands of incidents monthly. The losses incurred during the first six months of 2025 exceed $3 Billion! The bad actors come in all shapes and sizes, but in most cases the activity is driven by organized criminals exploiting gaps in our traditional payment method. Complicating the issue, financial institutions encounter perceived legal barriers hindering timely info-sharing about fraudulent activities, particularly related to “mule” accounts used by fraudsters to launder large sums. The uncertainty around privacy regulations often causes hesitation, delaying responses and giving fraudsters crucial time to cash compromised checks. However, organizations like NACHA and ECCHO, along with many national and local trade associations have established fraud directories to help improve timely communication among financial institutions. Additionally, there is proposed legislation to create a Federal Payments Fraud Task Force, to help bring a coordinated effort to respond to this nationwide threat. Community FI’s can proactively mitigate these risks by strengthening their internal controls, training both frontline AND back-office staff and by implementing advanced fraud solutions. There are service providers who can significantly enhance detection by quickly identifying suspicious checks at the point of deposit, helping banks prevent fraudulent transactions – before losses. Adopting Positive Pay systems, regularly updating customer education initiatives and enhancing internal communication channels can all reduce vulnerability. Given the ongoing threat, FI’s must be vigilant. Stay informed, implement proactive measures, and collaborate with your peer FI’s and trade associations. Information sourced from  Kathy Field, Finovifi

Ryan Wedel has joined The Bankers Bank as Senior Vice President of Commercial Lending, bringing with him almost 30 years of banking experience – the last 16 years at Landmark National Bank in Kansas. While at Landmark, Ryan successfully led the Commercial Lending team across both metropolitan and mid-market areas, including Kansas City, Lawrence, Topeka, and Manhattan. He most recently served as Landmark’s Chief Strategy Officer, where he drove strategic initiatives and innovative solutions. Ryan graduated cum laude with a Bachelor of Science in Finance from Emporia State University where he played basketball for the Hornets.  He later attended the Graduate School of Banking at Colorado and was awarded the Certificate of Excellence. Outside of his professional endeavors, Ryan remains actively engaged in community events. He and his wife, Caitlin, have been happily married for over 15 years and are proud parents to two daughters. Their daughters participate in various sports, including soccer and volleyball, keeping the family immersed in an active lifestyle.

This year TBB returned to the Quail Creek Country Club for its Annual Shareholder Meeting. We were able to recognize outgoing board members Barry Anderson (F&M Bank), Clayton Lodes (First National Bank and Trust Company of Ardmore), and Richard Sims (Wellington State Bank) who have helped lead the bank to its most profitable years ever. Clayton served as Chairman for the past year and stated that TBB is in good hands with its current board and management leadership.  CEO Troy Appling talked about the past year for the entire Bancorp. Forward in Technology continued to provide exceptional IT service to banks. Our audit firm was rebranded to The Bankers Solutions (TBS), doubled its staff, and added new services such as loan review and HR consulting.  The word for TBB at the Shareholder Meeting was extraordinary. Based on solid loan growth and some extraordinary items, TBB had the best year in its 38-year existence. As a result, shareholders were thrilled to learn that the Bancorp was paying a $25/share dividend totaling more than $1.7 million.  The Shareholder Meeting is a great opportunity to learn more about what is happening at the bank and for the Board and Staff to thank shareholders for the investment they have made in the company. Because of them, TBB and its affiliates help community banks thrive in a competitive banking environment, now and throughout 2025. John Tom Anderson John Tom has been in banking for more than 45 years and currently serves as a director and CEO of F&M Bank in Edmond, Oklahoma. John Tom is the son of one of TBB’s founders, John V. Anderson, and this is his third term on the Board of Directors. He also serves on the Board of Directors for Sovereign Bank, United Life Insurance Agency, F&M Insurance Agency, and the Citizens Potawatomi Nation Gaming Commission.    John Tom is an alumnus of the Graduate School of Banking at the University of Wisconsin-Madison. He has served on the FDIC’s Minority Depository Institutions Subcommittee to the Advisory Committee on Community Banking and has been inducted into the Choctaw Hall of Fame. John Tom and his wife Brenda have 3 children (Amy, J.T. and Zane) and 8 grandchildren.  Evans McBride A forty-year banker, Evans currently serves as President and CEO of First National Bank & Trust Co. of McAlester where he has been since 2006. This is his third term on the Board of Directors, and he is a past Chairman. Originally from Texas, Evans obtained his Bachelors degree from Angelo State University and graduated from the Graduate School of Banking at Louisiana State University.  Evans is a leader for numerous organizations. He is a Director for the Oklahoma Bankers Association, Trustee for Advantage Health Plans Trust, past President of the McAlester Area Chamber of Commerce & Agriculture, past Board Member of McAlester Regional Health Authority as well as Eastern Oklahoma State College – just to name a few. Evans and his wife Amy have two sons and are members of the First United Methodist Church.  Casey W. Barrett Casey is the President and CEO of Texas Bank in San Angelo, Texas, where he has served since 2018.  A long-time TBB customer, this is Casey’s first term on the Board of Directors. He is very active in the San Angelo community and is a member of the San Angelo Health Foundation Board of Trustees, San Angelo Stock Show and Rodeo Executive Committee, San Angelo Water Advisory Board, along with serving as a Deacon for Glen Meadows Baptist Church.   Mr. Barrett started his banking career as a State Bank Examiner for the Texas Department of Banking before entering the “other side” of banking as Chief Financial Officer for Texas Financial Bank and then as Executive Vice President-Senior Lender for First National Bank of Ballinger.  He is committed to community banking and proudly serves on the Texas Bankers Association Board of Directors as Government Relations Chairman and as a Trustee for Advantage Health Plans Trust representing banks across Texas, New Mexico, and Oklahoma.  He is a graduate of Texas Tech University as well as the Southwest Graduate School of Banking at Southern Methodist University.  Casey and his wife, Kaley, have three daughters, Rylee, Preslee, and Allie.

by Kas Stewart, SVP & AAP ACH NETWORK If your bank provides international wire services, this proposal will create an alternative. NACHA has issued a request for comments, which are due by May 30, 2025. The purpose of the change is to increase the usefulness of this transaction. In 2024, there were 121 million IAT debits and credits processed. In addition to the proposed changes to IATs, there are two items that pertain to all ACH payments. One would specifically define what valid characters are for ACH records and the other would have the current Return Reason Code R16 apply solely to frozen accounts. For details, log on to the NACHA website.  LET’S GO TO THE MOVIES!! ISO20022 If you are still struggling with the change to the existing wire format, which will be implemented on July 12, 2025, and applies to every financial institution, please take time to review webinars that were presented at various times by the Federal Reserve. These are on demand on YouTube. Search for Fedwire Funds Service. You will find an introduction and overview, My Standards, Tools and Testing and a deep dive on customer transfers.  Are you ready? If you have not done so, please inventory the systems that support your wire operations like wire forms, online banking, mobile payments, treasury operations, compliance screening, fraud monitoring, accounting, and billing. Ensure that your internal software developers or vendors have acted and are ready. Call The Bankers Bank, if you have questions or if you believe you are ready for July 12 and you would like to begin testing. OUR OLD FRIEND, FEDNOW! Participation levels continue to increase with over 1300 financial institutions  using the network. If you are still hesitant about usage, this is an innovation that would provide a new product to your customers, could increase revenue, and could be a customer retention tool. Fed has said the service is safe, efficient and has some tools in place to monitor risks.  These include a negative customer list and the ability to set up thresholds, which will allow you to define value and velocity thresholds by customer segment to fit customer needs and risk tolerance. Let us know if we can help you.

Korbet Moore is a finance professional with experience in credit underwriting, compliance and consulting. He has worked for several years as a consultant, specializing in loan review, interest rate risk analysis, collateral risk management and policy audits. Korbet has developed expertise in stress testing and financial scenario analysis, particularly in relation to asset and liability management. While earning his finance degree at Oklahoma State University, he served as an intern with Cattlemen’s Bank through the Oklahoma Bankers Association, gaining valuable experience in the banking sector. Korbet is committed to helping banks optimize financial operations and manage risks effectively. The Bankers Solutions (TBS) is a sister company to The Bankers Bank and Forward in Technology .  TBS’ team of eight bankers has performed compliance audits and internal audits for banks in Oklahoma and Texas for over 20 years. TBS has expanded their footprint into New Mexico and Kansas, and now provides even more services including outsourced internal audits, credit reviews, interest rate risk reviews, HR consulting, and other consulting services.

by Kas Stewart, SVP & AAP ISO20022 It is difficult for me after these many months of including ISO2022 as a hot topic to continue to think that it is hot, but it is!  I open every article with more information about ISO20022, and this article is no different.  Although the targeted implementation day of March 10, 2025, has been postponed until July 14, 2025, the transition to ISO20022 continues to move forward.  We are restricted from sharing the actual format with you, but The Quick Reference Document from the Federal Reserve provides a look at some of the changes in format and terminology that you will be seeing.  The Bankers Bank continues to prepare, test and be ready for this notable change for you and your customers.  Readiness extends beyond the wire format and includes readiness of internal and external systems that support wire transfers, upstream and downstream and client facing systems that support wire transfer operations. We have previously discussed recurring wires and  your ability to copy old wires.  All wires are maintained on our system for 10 years for your reference, but you will not be able to copy those old wires as they are in the old format. Every payment made from July 14 and going forward will be a new payment.   The existing wire system will have an orderly close on the implementation date, at 7 PM, EST. Your staff  should make certain that all incoming and outgoing wires have been processed and that there are no wires “pending” prior to that close.  This new format will be faster, more efficient and will standardize the US with other global payment systems.   The Treasury Department will only accept ISO20022 structured data starting July 14, 2025. Please call us if you have questions or concerns. FASTER PAYMENTS FedNow, the first new payment rail in 50 years, is growing. This product was launched in July 2023 with thirty-five participants and has now grown to more than 1,000. Many participants are currently only receiving entries. Financial institutions are being encouraged to be innovators, increase your return on investment, provide more and better customer service and garner some revenue. The system is very efficient and automated, which ends the need for staff to be on the clock and all you need to do for those benefits is enable the send side of FedNow. If you are considering FedNow or the send capability in FedNow, begin to target users, be selective as not all customers will have a need. Look for minimal risk opportunities like your own loan disbursements, or your vendors, real estate transactions, or insurance claim distributions. Fed continues to waive their monthly fee of $25; transaction fees are $.045; and a request for payment is $.01. Please call us if we can answer other questions or can help you in any way.  CHANGES TO POSTAL MONEY ORDER The U.S. Postal Service is redesigning money orders and enhancing security features. Ink on the new money orders is red and blue with an American flag and an eagle head. There will be a watermark that is only visible when held up to the light, a vertical security thread only visible when held up to the light and a QR code that is directed to the USPS website. The USPS is not revealing all security marks, but money orders are among the most secure instruments in the world. The USPS routing number will be changed to 0000-0119-3. Be sure your system will be able to process the updated routing number. This design will be available to the public in early 2025. SAVINGS BONDS Financial institutions now have the option to not cash savings bonds for both non or new customers. Bonds can be cashed for established customers (12 months). Customers can also be referred to Treasurydirect.org for both purchase and redemption of bonds.

by Miles Pringle, EVP & General Counsel Dwight D. Eisenhower once said: “In preparing for battle I have always found that plans are useless, but planning is indispensable.”  While banks are required to have a strategic plan, examiners are quick to note that there is no one “best” approach. Instead, regulators focus on the reasonableness of the plan’s assumptions. Their assessments consider many factors such as a bank’s personnel resources, geography, financial resources, and operating circumstances. Sound strategic planning is crucial to successful performance in the face of uncertainty and change.   According to the FDIC Examination Manual, examiners should consider the following when assessing the adequacy of the strategic planning process:  How formal is the bank’s planning process compared to the bank’s business model, risk profile, size, and complexity?  Were the right people involved? The board? Middle management?  Is the plan based on realistic assumptions regarding the bank’s present and future financial condition, market area(s), and competitive factors?  Does the bank monitor actual performance against its plan?  Does the bank consider alternative plans in response to changing conditions?   Some banks may be able to internally develop a satisfactory strategic plan. With that said, community banks need to do more with less, and comply with many other regulatory requirements, so strategic planning may be a good project for which to seek outside help. This start to a new year might be a good time to consider current strategic planning processes.  A good strategic plan will forecast internally (e.g., what people do we need?) and externally (e.g., what are our competitors going to do?). The plan should set your bank’s goals and describe how to measure those goals. Generally, a 3–5-year plan is best. Shorter plans are likely less ambitious and will not move the bank. Longer plans can delay necessary changes and will be less useful in later years because it is harder to predict the future the further out one goes.  Finally, and most importantly, strategic plans should be dynamic, not static. When assumptions prove wrong, they should be revised. When goals are accomplished, or become less important, they should be revised. A strategic plan is not a script, it is a tool to prioritize goals for success and avoid risk. As stated by the great Benjamin Franklin, “By failing to prepare, you are preparing to fail.” Make sure to talk to TBB about your strategic planning needs. We have resources that can help with your planning, including PRINGLE® Strategic Plans for Community Banks.

In addition to being Board Chairman for The Bankers Bank, Clayton Lodes is CEO at First National Bank & Trust of Ardmore, OK. He is a CPA, and practiced public accounting for over 20 years before joining 1NB in 2002. Clayton has served on the TBB Board since 2018, and also serves on the REI Oklahoma Board of Directors in Durant. He and his wife, Bebe, enjoy volunteering for several civic and charitable organizations and especially enjoy spending time with their three children and five grandchildren. Q: How has your term as Chairman been? A: My time as Chairman has been very rewarding.  Communication between the Board and Management Team is excellent, and I could not be more pleased with the progress we have made this year.  Our strategic planning meeting was effective and initiatives from that meeting are well underway.  Operations are running smoothly, and we are on track for another record earnings year.   Q: What do you value most about TBB? A: TBB has been a strategic partner of First National Bank & Trust Company of Ardmore for many years.  Our bank uses a significant number of products and services offered by TBB and have found them to be of very high quality, competitively priced with outstanding customer service.  The management team and staff work closely with many banks and a variety of vendors, so they are a valuable resource for us as we navigate a changing environment. Q: What do you see for TBB in the future? A: TBB is highly respected by the banking community in our market area and is also considered an innovative leader among correspondent banks across the country.   We are constantly developing and enhancing products and services needed in the industry.  Our innovative team continues to cultivate relationships and provide solutions for other correspondent banks.   As a result, our market area and client base are expanding.  With a clear vision and this high performing team, I believe TBB is well positioned for continued growth in the future Q: Do you have any advice for fellow bankers? A: If you are not familiar with all the new products and services offered by TBB and its subsidiaries, (TBS) The Bankers Solution and (FIT) Forward in Technology, you should give them a call.  You will be glad you did. Q: What activities do you enjoy outside of banking? A: Enjoying quality time with family and friends is on the top of my list of favorite activities. I also enjoy almost any outdoor activity including fishing, hunting, shooting sports and an occasional sky-diving excursion with other old bankers. Q: Any other message for TBB customers and shareholders? A: TBB has not only been a tremendous financial investment for our bank, but it has also been an invaluable resource for our management team!  If you are looking for a solution, make TBB your first call!

by Miles Pringle, EVP & General Counsel You may have seen news in early September that social media videos (largely on TikTok) were showing people exploiting a “glitch” in Chase Bank’s ATM system. The error allowed customers of Chase Bank to write a check for more money than they had available, deposit the check via ATM, and then withdraw the funds in cash. Not long thereafter, Fidelity Investments reduced mobile deposit limits for certain customers, citing a similar scheme. These are examples of new forms of check kiting.   There have been other concerns regarding check fraud as well. Earlier this year the American Bankers Association and the U.S. Postal Inspection Service announced a joint effort “to combat the rapid rise in check fraud, which has increased nationwide by 385% since the pandemic, according to the U.S. Treasury Department. Check fraud schemes commonly target the U.S. mail to steal checks, alter or wash them to change the payee and dollar amount, and ultimately steal money from victims’ accounts.” It appears that criminals are replicating keys to mailboxes (such as the blue drop-off boxes) or even creating fake ones in highly trafficked areas.  Checks are a significant form of fraud for a few reasons. One, checks have a slower settlement schedule allowing bad actors to exploit the time lag. Another reason is that they are physical instruments until scanned, so they can be stolen and altered fairly easily. While every payment method can be involved in a fraud, according to NACHA: “Checks continued to be the most problematic payment method.” The reports regarding the demise of checks have been greatly exaggerated, and checks will be an important form of payment for the foreseeable future. While the number of checks written has been declining since 2000, the value of money transmitted via checks has stayed relatively flat since 2012. Thus, as noted by the Federal Reserve in its most recent Payments Study, the average value of every check written is actually increasing (for example from $1,908 in 2018 to $2,430 in 2021).  So, what can banks do? Unfortunately, there is no silver bullet. Instead, banks should take a layered approach. Banks can invest in technology solutions and implement programs for riskier customers like Positive Pay. Knowing your customers, and putting transaction limits around riskier customers, is an important tool as well. Perhaps the best tool is customer education. Banks can make sure their customers know of common fraud schemes in order to avoid them in the first place!

by Kas Stewart, SVP & AAP NUMBER 1: FDIC Signage The FDIC has amended Part 328, Subsection A and B governing the use of the FDIC signage. Compliance with subsection B is required by January 1, 2025. This section, FDIC Official Signs and Advertising Requirements, False Advertising, Misrepresentation of Insured Status and Misuse of the FDIC’s Name or Logo was approved by the FDIC Board in December 2023.  Compliance with Part 328, Subsection A has been extended to May 1, 2025. This section applies to the provisions requiring (1) the use of the FDIC official sign, official digital sign, and other signs differentiating deposits and non-deposit products across all banking channels, including physical premises, ATMs and digital channels, and (2) the establishment and maintenance of written policies and procedures to achieve compliance. The final rule also establishes a new black and navy-blue FDIC official digital sign. Banks will be required to display the official digital sign near the name of the bank on all bank websites and mobile applications and certain Automated Teller Machines. Details of this change are available on the FDIC website as well as in the Federal Register Notice. NUMBER 2: ISO20022 What is this? The new language of payments. This change will be efficient, fast and will standardize the US with other global payment systems. When is this effective? The Federal Reserve has selected a single day implementation system with all financial institutions converting on March 10, 2025. The existing wire system will have an orderly close on March 7, 2025, at 7 PM EST. The Fed will sunset the current wire format (FAIM) and it will no longer be available. Is Bankers Bank ready? The Bankers Bank has been working diligently on this change, has been certified and is working on other components that lead to full readiness. Getting The Bankers Bank ready for our customers is a key piece of this change, but we cannot do it all. What do I need to do? Act Today! Please inventory upstream and downstream systems that support your wire operations including client facing systems, Office of Foreign Asset Control (OFAC), anti-money laundering, fraud monitoring, accounting, billing, or cash management and Treasury operations. Reach out to those vendors to ensure their readiness.  Where can I get more information?  The Federal Reserve has many resources in the ISO20022 Implementation Center.  Google: Fedline Advantage users get ready for ISO20022 and you will find information on training, the next drop-in online seminar - December 4 (must register), the next testing date - January 25, 2025, and the format.  There are On Demand webinars available on YouTube, A Preparedness Checklist, and an offer to subscribe to On the Wire ISO20022 Newsletter, and of course FAQs.  Most impactful for you! Existing wire templates cannot be copied into this format. Every wire will be a new payment. This applies to wire templates as well as import/upload of files.  NUMBER 3:  Faster Payments This product from the Federal Reserve has now been available for more than a year. The Federal Reserve recently hit another milestone with one thousand banks taking part in FedNow. Oklahoma has 40 financial institutions that have implemented the service. Most users are in the Receive Only category, so adding send capabilities will be a target and goal for you, your service provider, and the Federal Reserve in 2025. The Federal Reserve waived fees for 2024. Most service providers have implemented a fee structure, but many are starting to think about fees for the send side of the transaction. Have you considered what you would charge for a FedNow transaction? Have you discussed this with your core or service provider to see what their plans are? Because FedNow is like a wire: final and irrevocable, should the fee mirror what you charge for a wire? What will your customers expect? Do you have a marketing plan for this product? Is your service provider prepared to offer send capabilities or is that still in development? Have you considered how you will manage the balance in your account if you begin to send? The Bankers Bank is prepared to help with that process by offering a Liquidity Management Tool. Please reach out to your account representative for more details.  The Banker Bank is also a funding agent for Real Time Payments (RTP), and we would be glad to discuss that product with you. RTP has been processing faster payments for five years and can be an added service or an alternative to FedNow.  NUMBER 4 : Multi-Factor Authentication Several years ago, The Bankers Bank stepped away from the ID and password access to our on line product, iWeb, and offered a fingerprint scanner. Time has passed, our industry has changed, and data security and multi-factor authentication has become an industry standard. Use of the fingerprint scanner does not have a sunset date; however please consider moving to an alternate access method. We are reviewing other options, but we currently recommend and support the following two methods: Username/password/IPRestriction/YubiKey Username/password/IPRestriction/Google Authenticator Is Biometric not MFA? Biometric authentication verifies user identity using a piece of “who they are” and would require sophisticated technology to replicate, unfortunately it only compares one authentication factor. The Bankers Bank recommends banks follow the guidance in the FFIEC Statement on Authentication and Access to Financial Institution Services and Systems to perform a risk assessment.  Can I use both Google Authenticator and YubiKey? Absolutely. This decision may be made on a per user level. We want to give banks the flexibility to perform their own risk assessment and choose the best approach for them. How do I set/register my preferred method?  Contact TBB Operations NUMBER 5 : Brokered Deposits On July 30, 2024, the FDIC proposed some changes to Brokered Deposits that would reverse many of the provisions made in 2020 and require changes to relationships established during the past four years. The proposal is intended to strengthen the restrictions to reflect the FDIC’s experience since 2020, narrow the definition of brokered deposits, eliminate “exclusive deposit placement arrangement” and amend the interpretation of the primary purpose exception. If you have not commented on these changes, there is still time as the proposal deadline was moved from October 22 to November 21.