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The Bankers Solutions (TBS) is celebrating two years since rebranding from Bankers Professional Services, Inc. This new name represents more than two decades of experience helping community banks manage risk and compliance. The change was more than cosmetic. It marked the beginning of a period of significant growth for our team, our services, and the banks we serve. When we introduced the TBS name in August 2024, our team numbered just four people serving 34 banks, with a service lineup centered on compliance and internal audits. Two years later, TBS has grown to 12 team members serving 70 banks across Oklahoma, Texas, Kansas, and New Mexico. Our client base has more than doubled, with new relationships taking root in Kansas and our first proposal recently presented in New Mexico. That growth reflects a broader set of services. Alongside our bread-and-butter compliance and internal audit work, we’ve added Human Resource Consulting, Loan Review, and Interest Rate Risk Management reviews, giving client banks more tools to strengthen their operations through one trusted advisor. Revenue has grown right along with that expanded scope, more than doubling since 2023. Team growth has been just as important as client growth. Dustin Loeffler, our Executive Audit Manager, just celebrated his 15-year anniversary. He continues to anchor a group where most colleagues bring prior banking experience to the table, and our newest additions carry that tradition forward. Lindsey Brown-Acquaye joins as Senior Audit Manager, and she’s no stranger to TBS: she worked with us years ago before taking on senior compliance and risk leadership roles at banks ranging from $78 million to $3.2 billion in assets, including a fractional CRO-level engagement during an active Federal Reserve exam. We’re thrilled to have that expertise back in the fold. We also welcome Miracle Grayson as our HR Consulting Associate, supporting our newest service offering. More banks don’t just mean more revenue. They help our team gain experience across a wider range of institutions, challenges, and services every year. That breadth of experience is what we bring back to every client relationship, and it’s a big part of why banks continue to reach out to us for support. As we look forward, our focus remains on the mission that brought us here: being trusted advisors and resources to community banks through exceptional consulting, audit, and compliance services. Two years in, we’re proud of how far the team has come, and we’re energized by the opportunities to serve more banks and people in the years ahead. For more information on The Bankers Solutions, a list of services, or to get in touch with their team, visit their website at https://www.thebankerssolutions.com.

Charles Appling passed from this life on June 25, 2026. Charlie was a well-known banker who started his career at Dial Finance in 1964. He worked in the Oklahoma banking industry for over 50 years at FNB Bethany, FNB Rush Springs, FSB Lone Wolf and Southwest State Bank Sentinel. Charlie had a long relationship with The Bankers Bank. He sat on the Board of Directors for three terms between 1992 and 2015, serving as Chairman twice, and was the proud father of TBB’s President and CEO, Troy Appling. Golf was one of Charlie’s favorite pastimes; he played in the first TBB golf tournament in 1988 and every one since until the 37th annual tournament this year. Charlie’s joy of life, stories, and his presence will be greatly missed.

Faster Payments – Instant Payments There are two Networks: FedNow and RTP and they both work! Why two? These payments offerings have been available for some time, but many banks are not participating with either, or are using both (there is no interoperability). These networks provide every bank, large or small, with the ability to provide safe payment services 24/7/365. What is your bank’s position on faster payments? Volume and value continue to grow as well as use cases. Are you waiting for customers to express interest? Should you be proactively contacting business customers? Are your customers’ needs satisfied by using traditional options such as Wire Transfers or Same Day ACH? What do you need to do to offer these services? The first point of contact should probably be with your core system provider for a review of implementation plans, API development and associated fees. There are also other service providers, including The Bankers Bank, that offer the software. Lists are available on FedNow and RTP websites. Both Networks provide lists of banks and credit unions that use their services. I would recommend reviewing the list of participants. Are these banks and credit unions you would expect to send to or receive transactions from? All transactions are credit push and all transactions are irrevocable. Both networks are real-time gross settlement in a matter of seconds. The Federal Reserve relies on master accounts for settlement. That means you can use a Master account directly at the Fed, or you can use The Bankers Bank’s master account, instead. Real-Time Payments require a prefunded account at the Federal Reserve in New York. If you have concerns about staffing 24/7/365, you can subscribe to a Liquidity Management Tool (LMT) with The Bankers Bank or another service provider that monitors and maintains a positive balance in your account after hours, on weekends and holidays. Some banks wonder how these networks compare to Zelle. FedNow and RTP provide bank to bank services, while Zelle is a person-to-person service, available on bank websites. Please reach out to your calling officer at The Bankers Bank if we can provide additional information or assist in any way. by Kas Stewart, AVP & AAP

The 37th annual TBB Golf Tournament was held at Oak Tree Country Club on Monday, June 8th. Players enjoyed sunny weather with just a hint of that Oklahoma breeze sweeping ‘cross the fairways. We celebrated our 40th year of business with a special logo on golf shirts and other give-away items. Thank you for your business! We appreciate our SPONSORS! We could not put on this event without them. We can’t say enough about our Bancorp volunteers who jump in wherever needed to make sure the players have a great experience each year. And Thank You to those that stay behind at the bank and keep everything running smoothly. Finally, thanks to all that came out to play. TBB is thrilled to host this event each year, and we look forward to seeing you next year. Mark your calendars – Monday, June 7, 2027. A Flight 1st: Tony Nichols, Taylor Nichols, Jaden Jackson, TJ Eidson 2nd: Jared Thomas, Tucker Holden, Jeff Adkins 3rd: Tres Wright, Rob Roberts, Worley Aitkin, Tanner Lewis B Flight 1st: Abel Castro, Kyler Tarr, Steve McIlhaney 2nd: John Tom Anderson, JT Anderson, Zane Anderson, Barry Anderson 3rd: Marcel Walther, Clayton Shumaker, Nolan Couch, Cameron Wilkins C Flight 1st: Don Tyson, Kem Crowell, Blake Clift, Stephen Mopope 2nd: Cole Martin, Bryan Petty, Stuart Weaver, Chris Longwell 3rd: Bryce Anderson, Jed Waggoner, Brian Henderson, Colton DeMuth View the Event Photo Album here!

Health care costs are climbing at their steepest pace in over a decade, with real implications for how you budget for your people and structure benefits. Here is the data, along with practical steps and broker conversations worth having now. What the Data Shows Mercer’s 2025 National Survey of Employer-Sponsored Health Plans, based on responses from more than 1,700 U.S. employers, projects total health benefit cost per employee will rise 6.5% on average in 2026, the highest increase since 2010, even after employers make plan design changes to soften the blow. Without any changes, employers estimate the increase would be closer to 9%. The average cost to insure each employee is now expected to exceed $18,500 in 2026, up from $17,496 in 2025, and 59% of employers say they are making cost-cutting plan changes in 2026, up from 48% a year earlier. Rising utilization of GLP-1 weight-loss medications, cancer treatment, and mental health services are among the leading cost drivers behind these increases. For a community bank on tighter margins than a larger corporation, an increase like this is hard to absorb without shifting cost onto employees. Employers nationally are responding with a more deliberate strategy rather than simply raising premiums, and there is real opportunity in following their lead. Worth Keeping in Perspective It is worth noting, briefly, that health insurance costs have been growing faster than wages nationally. Indeed Hiring Lab’s analysis of the Employment Cost Index found employer health insurance costs grew 5.7% year over year in the first quarter of 2026, compared to just 3.4% for wages, the fifth consecutive quarter in which insurance has outpaced pay. That is useful context for your overall compensation and benefits planning, but the more immediate opportunity is getting a real handle on the health care cost itself, which starts with a more detailed conversation with your broker. This is also a good moment to make sure employees see the full picture. A total compensation statement, laying out salary alongside the bank’s contribution to health insurance, retirement, and other benefits, helps employees see those benefits as a real, growing value add, especially in a year when premiums are rising. Many banks only issue these statements once a year; timing one to coincide with open enrollment, when premium changes are top of mind, can meaningfully shift how employees view their overall compensation, not just their paycheck. Questions Worth Bringing to Your Broker Before your next renewal conversation, it is worth pushing your broker past the standard renewal quote and into a more detailed discussion of your options. A few questions worth putting on the table: What would shifting a larger share of your population toward a high-deductible health plan paired with a Health Savings Account do to your overall spend, including both premium cost and the total cost employees see between premiums and out-of-pocket expenses? What alternative funding models, such as level-funded or self-insured arrangements, could apply to a bank your size, and what would your broker actually recommend based on your specific experience rating and claims history? A smaller institution’s risk profile can change which option makes the most financial sense. If you were to consider a network change, does the proposed network use a narrow or tiered provider structure to control costs, and what would that trade-off look like for your employees in terms of provider access in your specific footprint? These are the kinds of questions that move a renewal conversation from “here is what it will cost” to “here is what we can do about it,” and a broker who can answer them in detail is one worth having in your corner. Communicating Any Changes Employees managing chronic conditions, caring for aging parents, or raising young families feel plan design changes most acutely, and are often your most tenured, highest-context employees. Communicating changes early, explaining the “why” behind them, and offering a knowledgeable benefits contact during open enrollment tends to preserve goodwill even through a difficult renewal year. What Community Banks Can Do: Review plan design early; comparing PPO and high-deductible HSA-eligible options can meaningfully change your renewal number before you consider shifting cost to employees. Evaluate current GLP-1 and specialty drug coverage terms, and invest in preventive and mental health resources now; utilization-driven costs respond better to prevention than to cost-shifting alone. Bring your broker a specific list of questions, rather than waiting for the standard renewal presentation, so the conversation covers funding models and network design, not just this year’s premium. Health care costs are unlikely to stabilize without intentional planning. Banks that begin preparing for their 2026 renewal now will be better positioned to manage the impact. by Andrea Carter, SVP Human Resources

When you hear the words, Faster Payments, what do you think of? Is Same Day ACH among your options? Same Day ACH, a new faster payment, was implemented in September 2016. The usage has grown significantly from 13 million payments in the first partial year to 403 million transactions in the first quarter of 2026 with a value of $1.1 trillion. NACHA membership recently approved an increase in the dollar limit for transactions to $10 million, effective on September 17, 2027. Same Day ACH fees will not change but expect new use cases. Growth leads to change. Are you ready for the fraud monitoring rules that go into effect June 19, 2026? The Federal Reserve is also adding a new fraud mitigation service: Payee Name Verification. This service helps businesses prevent fraud by ensuring the name on the payment matches the intended recipient’s account. Monitoring services are commercially available. Explore your options and, of course, work with your originators, who could benefit from fraud reduction, error prevention, and enhanced security. Although the death of the paper check was predicted decades ago, checks live on and so does check fraud! If you have not explored the Federal Reserve Check Fraud Mitigation Tool Kit, I encourage a review of the components, which include basic information, fraud schemes, and educational videos. Google Federal Reserve Check Fraud Tool Kit for details. The Federal Reserve recently announced changes to cross-border payments. If these changes affect your institution, TBB’s International Department offers convenient access to international drafts and wires, foreign currency forwards, payment collections, banknotes in more than 100 currencies, and letters of credit. For more information, contact your calling officer or call The Bankers Bank and ask for the International Department. by Kas Stewart, SVP & AAP

At The Bankers Bank, our mission has always been simple: to make you, our respondent bank customers, more capable, more competitive, and more confident in serving your own communities. That mission extends beyond the financial products and services we provide. It extends to the technology platform that powers your connection to us. Over the past year, our Board of Directors has made a significant and intentional investment in modernizing and expanding our digital banking platform. This isn’t incremental maintenance. It’s a strategic commitment to building infrastructure that is modern, secure, and positioned to grow alongside the needs of the community banks and financial institutions we serve across Oklahoma, Texas, Kansas, and New Mexico. What This Investment Means for You The enhancements we have been working on reflect a deliberate focus on three priorities: reliability, connectivity, and transparency. Reliability means you can count on the systems that support your wire transfer activity, settlement functions, and interbank operations to perform consistently with the security controls and audit capabilities that today’s regulatory environment demands. Connectivity means reducing friction between your institution’s core systems and iWeb. We are building toward a future where your technology stack and ours work together more seamlessly. The work underway is designed to support modern integration standards that your core banking providers already understand. Transparency means giving your team better visibility into the activity flowing through iWeb. We want you to have the information you need, when you need it, and in a format that is actionable. The Board’s Commitment This investment reflects a clear directive from our board: The Bankers Bank must be a technology-forward correspondent banking partner, not just a well-capitalized one. Community banks deserve a correspondent that moves with the times and treats platform development as a core strategic priority, not an afterthought. The scope of what has been built, and what continues to be built, is substantial. Our development roadmap has been supported at the highest level of our organization, and we are committed to continuing that investment in the quarters ahead. Your Ideas Matter Most Here is something we believe deeply: the best ideas for where this platform should go next will not come from us. They will come from you. You are on the front lines of community banking every day. You know where the friction is. You know what your teams wish they could do faster, more easily, or with greater confidence. That institutional knowledge is exactly what should shape our development priorities. We are actively soliciting feedback from you, our respondent bank customers, and we take that input seriously. If you have a workflow that could be streamlined, a reporting need that is going unmet, or a feature you wish existed, we want to hear about it. Please reach out directly to Jeff Story, CITO, jstory@tbb.bank There is no formal process or lengthy form required. A simple email describing what would make your team’s experience better is exactly what we are looking for. Your perspective helps us build something that actually serves the people who depend on it. Thank you for your continued partnership with The Bankers Bank. We are proud to be your correspondent, and we are committed to earning that relationship every day. by Jeff Story, Chief Innovation and Technology Officer

Jake Charnock President & CEO First National Bank & Trust of Ardmore Jake Charnock serves as the President and CEO of First National Bank & Trust (1NB) in Ardmore, a role he assumed in 2022 after two decades of progressive experience within the institution. He joined 1NB in 2004, advancing through key roles including Credit Analyst, Commercial Lender, and Chief Credit Officer. Jake holds a Bachelor of Science in Accounting and a Master of Business Administration (MBA) from West Texas A&M University. He is also a distinguished graduate of the Graduate School of Banking in Boulder, CO (2013) and the local Leadership Ardmore program. Deeply committed to community and industry development, Jake is an active leader, currently serving on the boards of Ardmore Development Authority, Ardmore Regional Park Authority, The More Foundation and Community Bankers Association of Oklahoma. Jake and his wife, Julie, are dedicated community members and attend Emmanuel Baptist Church. They reside in Ardmore and are proud parents to their two daughters, Brooklyn and Presley. Brian Schneider President & CEO Blue Sky Bank Brian Schneider serves as President and CEO of Blue Sky Bank. He joined the bank in 2019, bringing with him more than 36 years of banking experience. Brian has served on the bank’s Board of Directors, contributing to the organization’s leadership and strategic direction. He has also served as a Board Member for Independent Bankers Association of Texas, Texas Bankers Association, Oklahoma Bankers Association, Community Bankers Association of Oklahoma and Co-Chair of Greater Tulsa Chamber of Commerce. Brian is a graduate of Southwest Texas State and holds an MBA from Oklahoma State University. His previous professional experience includes six years as Chairman and CEO of a $450 million bank in Texas, where he led the organization through a successful sale to a publicly traded bank at an above-market valuation. Prior to that, he was appointed President of a $2 billion bank serving in Texas, Kansas, and Colorado.

If you’ve been to a banking conference in the last year, you’ve heard the same thing I have: AI, AI, AI. Your board is asking about it. Your peers are claiming to use it. Your competitors are putting it in their marketing. And yet, when you ask people what they’re actually doing with it, the answers are quite vague. We all know AI matters; many just don’t know what to do with it. The good news is that the gap between asking the questions and putting it into practice is pretty small. What’s Working Right Now Think of today’s AI as a tireless junior analyst who never sleeps, never complains, and occasionally needs to be corrected. Used that way, it’s already paying for itself at community banks across the country. The highest-return uses we’re seeing today: Drafting and editing. Loan committee memos, board packet narratives, marketing copy, customer letters. AI gets you to a solid first draft in minutes instead of hours. (Full disclosure — I used Claude Opus to get the first draft of this very article.) Meeting summaries and action items. Microsoft Copilot handles your Teams meetings, and a device like Plaud captures the in-person ones. Either way, a 60-minute meeting becomes a one-page summary your team will actually read. Policy and procedure work. Updating an outdated policy, comparing your procedures against a regulatory change, or generating a first draft of a new SOP. Loan file preparation. Summarizing tax returns, financial statements, and credit memos so your underwriters spend their time analyzing rather than transcribing. None of these replace your people. They provide faster answers for your people. This is especially true for pattern recognition with financials and large amounts of data. Two Skills That Multiply Your Results Two things separate banks getting real value from AI from banks getting mediocre results. The first is prompting. Your team needs basic training on how to ask. A vague request gets a vague answer. A clear request — with context, an example of the output you want, and the audience in mind — gets something genuinely useful. The second is picking the right model for the job. Tools like Microsoft Copilot now let you choose which underlying AI model handles your request — Claude Opus, GPT, or Auto. The smarter models (like Opus) are better for complex analysis, nuanced writing, and anything regulatory. Auto is fine for quick everyday tasks. What to Be Ready For The next wave is moving from “AI helps me write things” to “AI helps me decide things” — with a human still in the loop. Underwriting assistance that flags risks and missing documents before a file hits the underwriter’s desk Fraud and AML pattern detection that surfaces unusual behavior faster than rules-based systems Internal knowledge agents trained on your own policies so a new hire can ask “what’s our process for a new depositor?” and get the right answer in seconds Compliance monitoring that reviews marketing materials and disclosures for issues before they become findings Don’t Skip Vendor Management Before anyone on your team types a customer name into a chatbot, you need an answer to a simple question: which AI tools are we allowed to use, and which ones are we not? Treat AI tools like any other vendor. Vet them for SOC 2, data handling, where the data is stored, and whether your inputs are used to train someone else’s model. Enterprise tools like Microsoft Copilot are built with business-grade controls. Public ChatGPT is not — and it shouldn’t be touching customer data. Then write a short, plain-language AI use policy that names the approved tools and gives clear examples of what’s okay (drafting an internal memo) and what’s not (pasting customer NPI into a public chatbot). One Last Thing AI can hallucinate — it’ll confidently make things up, including citations and regulations. The newer models are getting better at this, and some are specifically built to reduce it. You can also help by telling the AI directly: “If you don’t know, say you don’t know — don’t make it up.” That single sentence in your prompt does more than people realize. So, before you let AI anywhere near anything customer-facing or examiner-facing, have a human check it. If you’re not sure where to begin, you’re not alone. Forward in Technology is rolling out an AI Readiness and Governance service soon to help community banks with managing their AI usage. If that would be useful, reach out — we are happy to talk through it, no pitch required. AI isn’t going to replace community bankers. But community bankers who use AI well are going to have a noticeably easier time than those who don’t. by Andrew Johansen, President, Forward in Technology

What beautiful weather we had for this year’s golf tournament! The recent rain made for a wet, lush course, but there was no threat of a rain delay for the shotgun start. Just sunshine. We hope everyone enjoyed the return of the Grab & Go Breakfast and imbibed in the Club Specials and other offerings from the beverage carts and drink stations around the course. Play moved quickly with several teams finishing early, while others finished more leisurely. We are glad for whatever pace adds to your enjoyment of the day.  We appreciate our SPONSORS! So grateful! We could not put on this event without them. In addition to their sponsorships, several brought wonderful items to add to our prize table. So many winners! Thanks also to our TBB employees; those able to volunteer at the golf course, but especially those that remained at the bank to keep everything running smoothly.  Finally, a Big Thank You to all the players that came out to make the 36th Annual TBB Golf Classic such a success. TBB is thrilled to host this event each year, and we look forward to seeing everyone next year. Mark your calendars – Monday, June 8, 2026.  A Flight 1st:    Brandon Anderson, Casey Wolfe, Craig Martindale, David Welch 2nd:  Blake Clift, Don Tyson, Kem Crowell, Gavan Steinmetz 3rd:   MaCrae Brunker, Brock Walker, Robert Garton, Travis Reese  B Flight 1st:    Chay Shockey, Clay McCall, Ron Westervelt, Joe Geister 2nd:  Charlie Appling, Mick Thompson, Brian Appling, Brett Appling 3rd:   Kyle Mullen, Landon Radichel, Fred Peters, Jonathan Ackley C Flight 1st:    Josh Atkinson, Rob Roberts, Nok Thatvihane, Wayne Stone 2nd:   Bruce Benbrook, Jim Peck, Terry Cook, Chris Conn 3rd:   Mark Poole, Kendra Anderson, Tim Sheehan, Zac Johnson Longest Drive: Brandon Appling & Kyle Mullen Longest Putt: JT Anderson & Jim Segerstrom Closest-to-the-Pin: Keegan Grooms & Alec Monsee

Let’s talk about partnership. Lately, I’ve interacted with an increasing number of companies – mostly technology-related, of course. There is a Grand Canyon of difference between those that I think of as vendors and those that I consider partners. With all the complexity and dependence on our technology stack, it’s increasingly important that our business relationships involve partners. Quick Gut-Check: Is it time to reevaluate? Though I hate to start this article negatively, I want to catch your attention with some things to consider – this is when you need to reevaluate a relationship. For many business relationships a partnership is important; I’d say the relationship with your Managed Service Provider (MSP) is one where true partnership is vital. If a few of these sound familiar, you might need to reevaluate. You have to ask multiple times to get the answers you need. You find out about changes after they impact your business. You’re told “that can’t be done” before you even finish explaining the goal. When mistakes are made, the vendor gets defensive rather than collaborative. Valuable Partnership Traits These are not just tech vendor characteristics, but are important for any relationship where shared success is a goal. Transparency (show me the real data) We’ve all seen vendor reports that are a sea of green checkmarks. Everything looks great…until you ask one follow-up question and discover the report was meaningless. Vague reporting can hide quite a bit: A backup report that shows “Success,” but doesn’t show trend over the last 30 days (or whether failures were quietly ignored). A security summary that lists “patching is up to date,” without showing what’s excluded, what’s pending, or what keeps failing. In reviewing these kinds of reports, I have found that the things a company leaves out often tell you more than what they include. In a good partnership, transparency means: We share mistakes early. No, we do not like mistakes, but ignoring them can be expensive. We talk about strengths and weaknesses. In doing so, we can encourage each other or pivot to a solution that has the most possibility for success. Reports reveal all the details about the services we provide. When, for example, a report shows that all machines are patched, but doesn’t detail a list of machines, it’s misleading reporting – the reader must be able to determine if the report encapsulates the full environment or only the conveniently successful machines. Partnership Story: FIT is a Microsoft-oriented company. When talking with a prospective client, we clearly define strengths in Microsoft and we are transparent about the tradeoffs with Google. Communication (useful and complete – not noise) We’ve heard it and lived it - solid communication is vital for a good relationship. With good partnership communication: Information is shared quickly and fully. Questions are answered completely (all parts, not just the easy part). If we see something that could help the other side, we share the information - because our goal is to strengthen both companies. Partnership Story: Kaseya is one of our critical vendors. A few years ago, Kaseya was the victim of a cybersecurity incident. As a splendid example of relationships with their clients, they called thousands of MSPs within just a few hours. This quick ownership and response greatly mitigated the scope of damage. In part because of Kaseya’s response to this incident, FIT is extremely loyal. Flexibility (outcome is more important than process) Rigidity in processes and services makes you focus on the process and not the result. Results-based cooperation requires flexibility. Processes are extremely important in our industry for consistency and reliability. But neither banking nor technology always fit a perfect formula. In the real world, flexibility gives us permission to use good judgment and collaboration. To be clear, flexibility in a partnership doesn’t mean chaos. It does mean that we work together and adapt when changes are needed. We do not hide behind our processes, but keep our eyes on the desired outcome. Partnership Story: I had a meeting with a client last week about phone systems. FIT provides VoIP as a service using a best of breed solution. This client is a nonprofit organization and thus can leverage incredible nonprofit pricing through Microsoft. In our conversation, we talked about FIT’s VoIP solution and the Microsoft Teams phone system. Because we focus on cooperative success, together we decided on an intentional exception to FIT processes in order to align with the client’s mission. Closing Question Is your vendor relationship simply transactional, or is it a partnership built on trust, flexibility, transparency, and strong communication? Because thriving in today’s cybersecurity landscape requires true partnerships. by Andrew Johansen, Forward in Technology

ACH RISK Management Rules The clock is ticking. Are you prepared? Are you preparing? Phase One: March 20, 2026 On this day, the rule applies to non-consumer Originators, ODFIs, Third-Party Senders; and Third-Party Service Providers with annual ACH origination volume of six million or greater in 2023. Phase Two: June 19, 2026 The rules go into effect for all other Non-Consumer Originators, Third-Party Senders and Third-Party Service Providers. What changes? NACHA currently requires RDFIs screen Web Debits and Micro entries. The amendment will require all ODFI, each non-consumer originator, Third-Party Service Providers and Third-Party senders to establish risk based processes and procedures to identify ACH items that are fraudulent. What are the new responsibilities? Many Financial Institutions already use systems for AML or BSA that could be extended to ACH monitoring. There are also Fraud Detection Platforms that would allow you to check velocity limits, anomalies, etc. There will be a new emphasis on mule accounts, dormant or inactive accounts, originator behavior, new senders, unexpected behavior or amounts. How do I prepare? How can you implement smarter, faster, risk-based processes and procedures? Do you want to develop this internally? Do you need to consider outside tech or vendor products? Have you approached your core provider? Educate your originators. Are they using multi-factor authentication or physical tokens? Do they authenticate requests for changes to existing files? Consider: Whatever you decide to do, monitoring must be consistent, auditable, and scalable. Your annual ACH Audit will now include a review of your process and procedures. Monitoring does not have to be done prior to processing. If you would like more detailed information search for The Payments Professor, Kevin Olsen, and his presentation, New Fraud Monitoring Rules (ACH), on YouTube. by Kas Stewart, SVP & AAP