Connecticut Banking 4Q 2018 by ambizmedia

The Official Magazine of the Connecticut Bankers Association

Fourth Quarter 2018

The Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018:

A GAME CHANGER For Banks & Local Communities

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Fourth Quarter 2018 • Connecticut Banking Magazine

COVER STORY

The Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018....................................................... 12

CONNECTICUT BANKERS ASSOCIATION

10 Waterside Dr. Farmington, CT 06032-3083 Telephone: 860-677-5060 • Fax: 860-677-5066

A GAME CHANGER For Banks & Local Communities

Chairman

Michael J. Casparino President-Northern Connecticut People’s United Bank First Vice Chairman

Stephen L. Lewis

President and CEO Thomaston Savings Bank Second Vice Chairman

Cynthia C. Merkle President and CEO Union Savings Bank President & CEO

Lindsey R. Pinkham Executive Vice President & Treasurer

Thomas S. Mongellow

First Senior Vice President & Secretary Colleen E. Clancy

FEATURES

KeyBank Poll Reveals Clients Aren’t Planning For Long-Term Care................................................4 Protect Your Bank Against Cyber Threats.............................6 TRID and “Gifts of Equity”— Still No Answers.......................8 New Banks as Bellwethers...................................................9

Connecticut Banking is an official publication of the Connecticut Bankers Association and is published quarterly by

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Stable Funds are More Important than Core Funds.................................................10 Bankers in the News...........................................................14 Banks in the News..............................................................16 3

Connecticut Banking Magazine • Fourth Quarter 2018

KeyBank Poll Reveals Clients Aren’t Planning For Long-Term Care By: Gretchen Miller, Senior Financial Planner, Key Private Bank Don’t have a long-term care plan? You’re not alone. As people live longer, the retirement population grows, and healthcare costs climb, long-term care is a critical component of family financial planning. Yet, despite a recent U.S. Department of Health and Human Services report that estimates people ages 65 and older have a 70% chance of needing long-term care in their lifetime, most people are not putting long-term care plans in place. This is true for high-net-worth individuals – those with assets over $1million – as well as people of more modest means. In a recent advisor poll by Key Private Bank, the majority of financial advisors surveyed cite fewer than 25% of their high-net-worth clients have longterm care plans in place. In fact, the biggest long-term care challenges my colleagues and I

face are convincing clients of the need for advanced planning, and helping them prioritize savings for long-term care costs with other financial goals. As a financial planner, I often have conversations with clients about the financial risks of aging. Consider a 2017 study by Genworth Financial that reports the current national median cost of a home health aide at roughly $49,000 annually, assisted living facilities at $45,000, and a private room in a nursing home at $97,000 – with a 5-year anticipated growth rate of 3%. Actual costs vary by region; here in Connecticut costs are closer to $53,000, $55,000 and $162,000 respectively. Many people underestimate the costs of long-term care or think that Medicare or their health insurance will cover everything.

Three Tips for Planning for Long-Term Care 1. Start planning early – financial advisors recommend long-term care planning occur between the ages of 40 and 50 2. Communicate your wishes – establish a family financial conversation to discuss your longterm care plans and wishes 3. Consider the costs – preserve your family wealth by taking steps now to plan for costs of potential longterm care needs

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Fourth Quarter 2018 • Connecticut Banking Magazine

That’s often not the case, and without proper planning, expenses can quickly eat up life savings. A financial advisor can help you define long-term care preferences, analyze potential costs, and create a deliberate financial plan to manage them.

Communicate your long-term wishes When asked about long-term care preferences, the vast majority of Key Private Bank advisors (96%) say their clients’ first choice is to stay at home and remain independent. When that is not possible, moving into an assisted living facility is a close second choice. Most do not want to rely on family or go into a nursing home. Despite strong preferences, advisors report their clients are not communicating enough to children and family members their wishes and future plans. Over half of advisors (55%) said only “some” of their clients are discussing long-term plans with family; two in ten (22%) say “hardly any” are doing so. As difficult as the topic may be, talking through with family potential end-of-life needs and management strategies is crucial for setting expectations, delegating respon-

sibilities, and avoiding misunderstandings or surprises. Family financial conversations should also include estate plans and your intentions about the ultimate disposition of your legacy. Be sure to discuss the terms of all your estate planning documents (wills, trusts and deeds, bank and investment accounts, etc.) and any life insurance and annuity policies. You should also discuss who has current authority to act on your behalf under the terms of a power of attorney and health care proxy, and any specific instructions you may have.

Start the planning process early The key to developing the best possible plan for your post-retirement future is to start the process early -- most advisors recommend conversations about long-term care at the outset of the client relationship. More robust planning should occur between the ages of 40 and 50. While financial advisors have differing opinions on the best approach for longterm care management (e.g. hybrid and annuity policies versus life insurance contracts with an accelerated death benefit rider, etc.), all agree that the earlier you begin, the bet-

ter financially prepared you will be when the time comes. Regardless of when you start, long-term care planning is ongoing. Remember that as life changes, so should your plan. Having regular communications with your advisor and family is the best way to keep your plans upto-date and in line with your lifestyle and care wishes. u Gretchen Miller is a senior financial planner at Key Private Bank who helps her clients plan for their financial futures. She can be reached at 203-784-5134 and by email at Gretchen_ miller@keybank.com. This piece is not intended to provide specific tax or legal advice. You should consult with your own advisors about your particular situation. Any opinions, projections or recommendations contained herein are subject to change without notice and are not intended as individual investment advice. Investments are: NOT FDIC INSURED • NOT BANK GUARANTEED • MAY LOSE VALUE • NOT A DEPOSIT • NOT INSURED BY ANY STATE OR FEDERAL AGENCY KeyBank is Member FDIC. KeyCorp. © 2018. CFMA 180703- 428086

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Connecticut Banking Magazine • Fourth Quarter 2018

Protect Your Bank Against Cyber Threats

y their very nature, banks are an attractive target for cyber criminals because of the assets they hold and the personal information of customers that they keep. Due to the evolving threats and uncertainty in today’s cyber landscape, it is vital for banks to take the necessary steps to guard against vulnerabilities and exposures, and to protect themselves from malicious attacks that can cause serious harm. A single breach can result in significant losses, and the damage is often not limited to lost data. It can extend to loss of customer confidence, financial harm, legal challenges and business interruption. Much like cyber threats such as ransomware, social engineering and phishing, cyber security has also evolved. Many insurance companies, including Travelers, offer risk management services that feature pre-breach cybersecurity expertise. These services go a long way toward strengthening the systems that banks use to keep cyber criminals at bay. In the event of a cyber attack, post-breach assistance kicks in, provided a bank has secured appropriate insurance coverage. Over the past few years, banks have increased their focus on preparing for a cyber incident – in other words, recognizing that when it comes to a network compromise, “it’s not if, it’s when,” even for a well-defended network. Banks are doing a better job of updating their incident response plans, business continuity plans, and disaster recovery plans, at least every one or two years, and they are conducting periodic tabletop exercises to make sure that the right people respond when an incident does occur. Stay-

ing up-to-date on cyber insurance coverage is another important part of being prepared. The tough thing about cyber security is that defenders have to be vigilant at all times, while attackers only have to get through the defense once to create havoc. For that reason, it’s important to have well-designed change control procedures in place to ensure that changes to network configurations and controls do not inadvertently introduce security vulnerabilities. Many network compromises can be traced back to change control procedures that either did not exist or were not properly followed. Implementing – and diligently following – established change control procedures can help prevent the mistakes that may lead to a data breach. How can banks best prepare for a potential cyber incident? There are many “best practices” for cyber security, but let’s highlight one that is particularly valuable for preventing complacency. Banks – all industries, really – should rotate their cybersecurity assessment and testing providers. If the same team is used for penetration testing year after year, they will likely find the same kinds of vulnerabilities year after year. Sometimes a new set of eyes can be beneficial. If a rotating group of trusted cyber-security assessment and testing providers consistently reports that a bank’s networks and systems are clean, the bank can feel more confident that nothing important has been overlooked. Being proactive is key – educating employees and putting proper risk management systems in place should be a high priority. Banks should work with an independent insurance agent to identify coverage to manage potential cyber exposures and ensure that employees are exhibiting behaviors that limit cyber risks. Finally, banks should utilize resources such as Travelers. com/cyber to help understand and navigate the growing threat of cyber risks. u

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Connecticut Banking Magazine • Fourth Quarter 2018

TRID and “Gifts of Equity”— Still No Answers By James Maguire, Associate General Counsel

n August of 2017, the Consumer Financial Protection Bureau (CFPB) finalized their changes to the TILA/RESPA Integrated Disclosures Rule (TRID). After what many called a disaster of an initial launch, these changes finally addressed lingering questions about the rule, especially in the areas of construction lending and simultaneous second lien purchase loans. Unfortunately, the changes still failed to address other continuing concerns, among them how to disclose “gifts of equity” on the Loan Estimate and Closing Disclosure. “Gifts of equity” are essentially a discount on the sale price of the property below market value. The seller agrees to sell the property to the buyer for X number of dollars below what James Maguire the property would go for on the open market; the X dollar figure is then considered a “gift of equity.” These “gifts” aren’t an issue with portfolio loans with a loan-to-value ratio (LTV) on the property below 80%—using the actual lower sales price as the value. The issues appear when the loan amount exceeds 80% of the actual sales price or in the case of investment loans— the issue being documentation as investors tend to require gifts of equity to be clearly disclosed on closing documents, or how a “gift of equity” must be factored into the actual sales price of the property for LTV purposes. So if you’re required to disclose a “gift of equity” somehow on the TRID forms, what to do? There are a few different schools of thought on this, and while there are slight variations for each, three basic approaches have been suggested. For the first approach (Approach #1), some believe this amount should be disclosed as “Downpayment/Funds from Borrower” and then offset with a negative amount in “Adjustments and Other Credits” in the Calculating Cash to Close table. (In Section L of the Closing Disclosure, the gift could appear in Other Credits, with a note that the fee is “P.O.C.” and paid by the Seller). For the second approach (Approach #2), others feel you should put the amount in Seller Credits, offsetting that with a positive number in Adjustments and Other Credits and a figure in Section K under “Adjustments”. For both Approach #1 and Approach #2, the “gift of equity” would be disclosed in Section N, too, effectively reducing the amount of money remitted to the seller at closing. Finally, for the third approach (Approach #3), still others feel like the best thing to do is simply to reduce the overall “Sales Price of Property” down to what the property actually is selling for (market price minus the “gift of equity”), and then mention the “gift of equity” amount in an addendum to the Closing Disclosure (leaving it off the Loan Estimate entirely). Each of these three approaches carries certain negatives. The first approach, for instance, seems somewhat to mimic the process for disclosing gifts from family members prior to closing. But as the commentary to the regulation states, “Amounts expected to be paid at closing by third parties not otherwise associated with the

transaction, such as gifts from family members . . . are included in the amount disclosed under [Adjustments and Other Credits].” It is clear that this approach is intended only for gifts from third parties, and not from parties involved in the transaction itself, which the seller would be. Secondly, this approach appears intended more for funds delivered at the closing table, as opposed to any gift delivered prior to or after closing as is arguably the case with a “gift of equity.” While the math may add up with this approach, it requires a stretch beyond the black-and-white regulatory language, and doesn’t quite seem to sync up with what the CFPB had in mind when disclosing ‘gifts’ on the Closing Disclosure. Regarding the second approach, while more straightforward than Approach # 1, it too requires a bit of fiction, as a “gift of equity” from the seller is not really applicable toward closing costs, and also requires a bizarre and unexplained positive offset in Adjustments and Other Credits just to make the Calculating Cash to Close table to balance out correctly. To make matters more troublesome, investors often limit any seller credit to a hard cap (such as 6% of the sales price), which could prove difficult for a large “gift of equity” being disclosed as a Seller Credit. The third approach appears to meet the investor requirement that the “gift of equity” be contained within the closing documentation; however, that gift of equity doesn’t mathematically factor into any of the calculations on Page 3, which may lead auditors, examiners, investors or even the borrower themselves to overlook the fact that a gift of equity was even present in the transaction. It also may create a discrepancy between the disclosed “Sales Price” on the Closing Disclosure and the “Sales Price” used to calculate LTV, which could give rise to questions of whether or not the disclosure is being presented in good faith. All the pros and cons being weighted, we feel like right now, the best approach to “a gift of equity” is in fact Approach #3: to disclose the lower sales price for the Loan Estimate and Closing Disclosure, and then mention the “gift of equity” in an addendum to the Closing Disclosure. First of all, this is supported by the regulation. Secondly, while this may at first glance appear to cause issues with LTV, note that federal real estate lending standards and the Sale Price figure do not directly pertain to one another—all the lending standards say is, “For loans to purchase an existing property, the term “value” means the lesser of the actual acquisition cost or the estimate of value.” They do not contain any crossreference to the TRID rules. Disclosing a lower sales price on the TRID forms and then mentioning the “gift of equity” in an addendum, both satisfies any investor requirements and also makes the math more simple for a borrower to understand; both of which are essential underpinnings of TRID. We feel that these benefits outweigh any generalized concerns about “good faith” regarding the disclosed sales price. continued on next page 8

Fourth Quarter 2018 • Connecticut Banking Magazine

New Banks as Bellwethers By Naomi Camper, ABA Chief Policy Officer

hen I joined ABA as chief policy officer in June, a task force of bankers with experience launching and running new banks were mid-way through their analysis of why “de novo” activity had stalled in recent years. Their mission—as established by Ken Burgess, ABA’s chair and die-hard de novo advocate—was to identify both challenges and solutions, in hopes of re-starting bank start-ups. As new as I was to ABA, I had no doubt why this was a critically important endeavor. Just as banks are central to the economic vitality of the communities they serve, new bank charters signify the economic vitality of the both the industry as well as our economy Naomi Camper as a whole. New banks signal optimism, opportunity and growth potential. The opposite—no new entrants—means less competition and fewer choices, which ultimately translates to less economic activity and growth, on which all banks depend for success. It may seem counter-intuitive, but existing banks are actually better off when we see a healthy pipeline of banks in formation—just as homeowners benefit when others are eager to buy into their neighborhood. I first came to appreciate the importance of a dynamic banking industry—populated with banks old and new, large and small—when I worked for former Sen. Tim Johnson (D-S.D.) as staff director of the Senate Banking Subcommittee on Financial Institutions. The South Dakota bankers who visited the office made sure I knew it, and my later experience working for JPMorgan Chase only confirmed it. That was in the early 2000s, when more than 100 new banks were chartered every year. Post-crisis, that number plummeted to fewer than two per year—and was yet another indicator that our economy and our industry had not yet fully recovered. The pace has started to pick up recently, along with the economy, but it’s still anemic. And that’s why Burgess convened the ABA De Novo Task Force, a banker-led effort to identify the essen-

tials for de novo success and major impediments to increased de novo activity. Many banks on the task force were started just before the financial crisis. Their resilience and success through the crisis and its aftermath reminds us that new banks can succeed in any environment. The task force agreed that successful de novo formation starts with selecting an experienced board and bank management team. De novos are poised for success when they combine their experi-

“ ...new bank charters signify the economic vitality of the both the industry as well as our economy as a whole. New banks signal optimism, opportunity and growth potential. ” ence with a strong business plan and the capital necessary to support that plan. Unfortunately, the current requirements for new bank formation prove to be more complicated. We recently presented our findings and proposed solutions to the FDIC, and the timing couldn’t be better. Not only is there new leadership at the agency willing to look into what may be impeding de novo activity, but the economy’s robust growth presents the opportunity to ensure bank entrepreneurs—and the customers and communities they wish to serve— benefit from the rising tide. If we can help change the course of de novo activity and facilitate new growth in the industry, we’ll be shaping a vibrant future for banking. u Naomi Camper is chief policy officer at the American Bankers Association.

Gifts of Equity continued from page 8

University of Minnesota Law School in 2007, he served as Assistant General Counsel for the Texas Attorney General in the Open Records Division, and later worked as a solo practitioner in the Austin area. Prior to joining Compliance Alliance in July of 2015, James assisted a major mortgaging servicer with the OCC’s independent foreclosure audit and was an SEC filing researcher for a major financial and legal research firm. He has extensive firsthand experience with open records, mortgage servicing, consumer law and securities regulation.

As with many things TRID, we continue to await guidance from the CFPB and other regulatory agencies on what the appropriate action for disclosing “gifts of equity” on Closing Disclosures will be going forward. In the meantime, please be sure to stick with Compliance Alliance for updates, and let us know if you have any questions regarding this perplexing topic! u James McGuire has worked as an attorney and legal researcher in the financial industry since 2010. After graduating from the 9

Connecticut Banking Magazine • Fourth Quarter 2018

Stable Funds are More Important than Core Funds By Donald Musso, President, FinPro Inc.

he current regulatory framework for funding and liquidity has some material shortcomings. These shortcomings include: the categorization of digitally originated deposits as noncore, the concern over large balance deposits, the concern over municipal deposits, and the inclusion of listing services as wholesale deposits.

Not all wholesale funding is risky and/or bad. A wholesale funding source, like a borrowing with a long term maturity, is stable whereas short term maturity is more volatile. The longer the term the more stable the wholesale funding source is.

“ It is time to finish the job and align liquidity analytics more closely to reality and true risk ”

To better assess liquidity risk, banks should establish a matrix that arrays the current regulatory funding categorizations of core, non-core and wholesale against short term volatility, long term volatility and stable funding. Donald Musso This new matrix arrays the current regulatory designations of funding against deposit stability. This matrix gets to the heart of the risk issue which is the stability of the funding source rather than a generic, non-risk aligned definition like core, noncore and wholesale. Within any of these three categories, funding can be short term volatile (very risky) long term volatile (less risky) and stable (little risk). For example, if a consumer opens a 1 year CD at a 1.00% rate physically in a branch it counts as a core deposit and is considered stable. If that same consumer, the same day, opens another 1 year CD at a 1.00% rate digitally, it would be noncore. Obviously the difference in designation makes no common sense as the funding source is identical.

To determine stability and volatility, banks need to determine customer and account loyalty using an approach similar to the FinPro Deposit Loyalty Score©. This analytical process arrays funding on a grid using stability markers. These stability markers were identified after conducting extensive liquidity analytics at a large number of banks. The markers include, but are not limited to, relationship, transactional activity, digital footprint, age, size, tenure and price. Each 10

Fourth Quarter 2018 • Connecticut Banking Magazine

FinPro Liquidity Matrix©

Short term volatile

Long term volatile

Stable Funding

Deposits < $250k Core Funding Non-Core Funding

Non Maturity Maturity

Municipal Deposits Large Depositors

Wholesale Funding

High Cost Deposit Calculation is critical

Non Maturity

Brokered Deposits Listing Service FHLB Borrowings

Maturity

100%

Internet Deposit assessment is critical

Deposits > $250k Valid “high cost” deposits Valid “internet” deposits

Loyalty Score 0-25%

Loyalty Score 25-50%

Loyalty Score 50-100%

Maturity 0-3 months

Maturity 3-12 months

Maturity 12+ months

Maturity

marker is assigned a weight based on its relative importance to the specific financial institution. Each weighted marker has a factor coefficient assigned to it based on institution specific bands. For example, the bands for a marker such as tenure could be less than 1 year, 1 to 3 years, 3 to 5 years and greater than 5 years. The longer the tenure the higher the factor coefficient assigned. The weighted average result is the loyalty score. The higher the score, the more stable the funding source is as shown in the liquidity matrix. While the process is complex, the end result is that all accounts have loyalty scores ranging from 0% to 100% that easily reflect their stability within the Bank. Intuitively this makes sense. For example, a large deposit that is from a material owner or family member of an owner, is stable. The size of the deposit itself does not determine volatility or stability. A $1 million dollar deposit from a Board member is much more stable than a deposit from single relationship customer that is less than $250 thousand. In a similar manner, municipal deposits are not a volatile source of funding simply because they are noncore by regulatory definition. Municipal funding can be arrayed to show balances over time and a minimum threshold can be established that would determine stable funding. For example, if a municipal deposit fluctuated between $1 million and $2.5 million in balance, the first $1 million would be deemed stable

and the rest volatile. Additionally, if the municipality is not shopping it’s accounts it could lead to stability. In our municipal example, if the municipality were to not shop the account for another 2 years, the whole balance would minimally be long term volatile. Listing service deposits should not be deemed volatile either. The vast majority of these deposits are time deposits with identical characteristics to internal bank time deposits. There is no broker involved, rather it is simply digitally originated. As such, listing service deposits should be treated like time deposits. The Regulatory relief bill started the process of designating funding types to more closely align with true risk. Changing the classification of reciprocal CDARs from brokered to core was an essential first step. It is time to finish the job and align liquidity analytics more closely to reality and true risk. u Donald Musso is President of FinPro Inc. He is a nationally known thought leader in Community Banking and a recognized expert in value creation for banks, strategic planning, loan and deposit growth, internal risk assessments, asset/liability management, customer segmentation and delivery alternatives, de novo bank formation and investment banking. He has started numerous denovo’s (several as a founder), is a large investor in Community Banks, is a member of various bank Boards and teaches for elite banking programs. He also frequently discusses community bank policy with all of the Banking agencies in Washington DC. Contact FinPro at 908-234-9398 or www.finpro.us.

The Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018:

A GAME CHANGER For Banks & Local Communities

n May 24, 2018, President Donald Trump signed into law the Economic Growth, Regulatory Relief, and Consumer Protection Act, which provides relief from certain rules and regulations for community banks. Among the law’s many provisions, one stands out in importance—most reciprocal deposits are no longer considered “brokered deposits.” This change benefits banks and local communities across the United States in a number of ways. In particular, it helps Main Street banks to attract and retain a greater amount of deposits that behave like core deposits from local customers by expanding the availability of deposit funding for such banks; providing banks with more funding to make loans available within their communities; potentially lowering the cost of funding for banks over time; and enabling such banks to help customers safeguard deposits above $250,000 and compete for stable funding.

DEPOSITS SENT TO ICS /CDARS NETWORK BANKS

LARGE DEPOSIT WITH A BANK

< $250,000

IN PRINCIPAL AND INTEREST

MATCHING DEPOSITS SENT BACK TO BANKS

deposit accounts and money market deposit accounts, whereas the CDARS service provides that access on funds placed into CDs. The safety-conscious customer is often a government organization (such as a city or county treasurer or a public school district), an institutional investor, a nonprofit, or another depositor that would otherwise make a large deposit in a large money-center bank, rather than a community bank (foregoing access to FDIC insurance for most of the deposit and relying on large rating agencies, like Standard & Poor’s and Fitch, and then tracking the ratings over time); require that a bank collateralize or otherwise secure thedeposit with Treasuries or other ultra-safe, highly liquidgovernment securities (an added cost for the bank andone that could lead to the customer receiving a lowerinterest rate if the bank adjusts its rate to compensate for the added cost it incurs); or manually split its large deposit among multiple banks, maintaining relationships with each (which requires negotiating different interest rates, signing multiple agreements, receiving multiple statements, etc.).

What Reciprocal Deposits Are and Why They Matter In the past, many large-dollar depositors, such as public entities, institutional investors, and nonprofits, were reluctant to deposit their cash at small banks because their deposits could only be insured up to $250,000; they feared losing money if their bank failed. In effect, small banks were often penalized for their size on the mistaken belief that small automatically equalled risky. This changed in the fall of 2002 when Promontory Interfinancial Network began offering the first “reciprocal deposit” placement service—CDARS® and, later, another one called Insured Cash Sweep®, or ICS®. Reciprocal deposits are deposits that a bank receives through a deposit placement network in return for placing a matching amount of deposits at other network banks.1 Although there are a number of providers, the leading reciprocal deposit placement service in the United States is operated by Promontory Interfinancial Network, LLC, which invented reciprocal deposits and offers two of the nation’s largest reciprocal deposit placement services mentioned above, ICS and CDARS. Nationwide, thousands of banks use these services to provide safety-conscious customers with access to FDIC insurance beyond the traditional $250,000 per insured bank, per depositor (technically, for each account ownership category). The Insured Cash Sweep service provides access to FDIC insurance on funds placed into demand

Insured Cash Sweep and CDARS are popular services because they enable safetyconscious customers to access multi-million-dollar FDIC insurance through a single bank relationship. Bank customers enjoy peace of mind and the convenience of working though one institution. Participating banks enjoy the ability to grow relationships and deposits from a local customer base without losing either to larger, toobig-to-fail institutions; without the added costs or tracking burdens associated with ongoing collateralization requirements; and with the ability to turn around and lend these relatively low-cost funds locally. At the end of the day, it’s a win-win for banks and their customers. But how this all comes together matters. 12

How Services Like Insured Cash Sweep and CDARS Worak

so long as the bank does not receive an amount of reciprocal deposits that causes its total reciprocal deposits to exceed a previous fourquarteraverage.3 These changes have positive implications for the banking sector. Banks now have a much larger, approved source of stable deposits that can be tapped. Furthermore, banks will be able to replace more expensive deposits, like brokered deposits, routinely collateralized deposits, and those from listing services (generally associated with wholesale pricing and no loyal or local customer relationship), with reciprocal deposits, like those available using CDARS and Insured Cash Sweep. These are generally lower-cost deposits that are eligible for multimillion-dollar FDIC insurance and that come from local customers at rates that banks set. Bank customers will also benefit in a number of ways from this change in law. Now, banks can help even more customers—including businesses (large and small), nonprofits, municipalities, financial advisors, and even individuals—to safeguard their funds, potentially at even higher levels, while at the same time attracting locally priced, large-dollar deposits, the full amount of which can be used to make loans locally. This helps communities across the United States. Of note, the ability to offer reciprocal deposits can be critically important to banks located in disadvantaged/underserved communities. These banks tend to rely more heavily on the ability to offer large-dollar access to FDIC insurance to attract deposits from socially responsible investors. Deposits from these investors are then used to fund local lending initiatives (e.g., infrastructure improvements, low-income housing, education, and other important activities) that otherwise might not take place. u

The mechanics of different reciprocal deposit services vary. With Insured Cash Sweep and CDARS, a participating bank can offer access to FDIC insurance beyond $250,000 because its customer’s original deposit can be split into smaller increments—each below the standard FDIC insurance maximum— and placed into deposit accounts at a large number of other banks. This process enables a customer to access coverage from many banks while working directly with just one (and, generally, receiving just one regular statement per service).

Bank-to-Bank Connections – Helping Community Banks Help Each Other So why would a bank agree to take Insured Cash Sweep or CDARS deposits from another bank, essentially helping that other bank? Because in a reciprocal service, it is doing the same thing with its customers and sending an equal amount of customer deposits to other banks (generally with help from a sophisticated matching engine that connects participating banks with each other based on different variables, such as the total amount of a customer’s deposit). Exchanges occur on a dollarfor- dollar basis so that each participating bank comes out whole. In other words, each participating bank reciprocates—thus, the term reciprocal deposits.

The Economic Growth, Regulatory Relief, and Consumer Protection Act The Act recognizes something that many in the banking sector have long understood: reciprocal deposits behave like core deposits; they are “sticky” (CDARS reinvestment rates are approximately 80 percent), and the institution accepting the deposit maintains a relationship with the depositor—almost always a locally based depositor.2 The new law acknowledges that reciprocal deposits are uniquely different from brokered deposits. Specifically, the law amends Section 29 of the Federal Deposit Insurance Act so that reciprocal deposits held by an FDIC-insured depository institution are not considered brokered deposits as long as: In addition, a bank that drops below well capitalized can continue to accept reciprocal deposits without a waiver from the FDIC,

Published white paper by Promontory Interfinancial Network.

FOOTNOTES 1. Most state laws expressly permit the use of reciprocal deposits by public entities, and they define reciprocal deposits in similar ways, generally adding that the maturities, if any, of the deposits placed and received, as well as the amounts, must match. 2. Through 2/28/18. Promontory Interfinancial Network calculates the reinvestment rate by determining whether a particular customer’s funds were reinvested within 28 days of maturity. 3. As under current law, interest rate restrictions will apply.

Connecticut Banking Magazine â&#x20AC;˘ Fourth Quarter 2018

James Garnett

Trish Fontes

Robert Mallozzi

Drew Williams

Jay McGuinness

Jennifer Pensa

Diane Arnold

Rose McLaughlin

Marla Bogaert

Lynda Hunnicutt

Debra Brown

Aya Beckles Swanson

Paul McNamara

William Catanzaro

Maria Bivona

Diana Serrano

Brant Walker

Renee Pallenberg

Shalonta Ford

Michael DeBlieux

Lee Foo

Kristen Sibley

Matthew Terribile

Laura Gallinoto

Jane Pinho

Mohammed Hassan

Kalim Jan

Christina Stone

Suzanne Hardy

Luciano Verdura

Bankwell James Garnett joined the board of directors. Trish Fontes was promoted to director, treasury management sales. Robert Mallozzi joined the Waveny Park Conservatory Board. Chelsea Groton Bank Drew Williams joined as a retail loan officer. Jay McGuinness joined as vice president, commercial loan officer. Jennifer Pensa joined as senior vice president, director of operations. Essex Savings Bank Diane Arnold was thanked for serving Old Saybrook Senior Housing Board for 8 years. Rose McLaughlin was elected as the incoming president to the Madison Chamber of Commerce. Marla Bogaert was recognized as an outstanding volunteer by Middlesex County Community Foundation. Lynda Hunnicutt was promoted to vice presidentbranch administrator. Denise Goucher was promoted to vice president, deposit operations. Debra Brown was recognized for her work by the Middlesex County Community Foundation as an 'Unsung Hero" for her numerous years of behind the scene efforts to aid Angel Charities' Angel Ride. Aya Beckles Swanson joined as vice president, commercial loan officer. Fairfield County Bank Paul McNamara will be stepping down as Chairman after 31 years.

First County Bank William Catanzaro was hired as vice president, commercial banking officer. Robert Granata, Noah Lapine, Edward Marcantonio, James McArdle III, and Ryan Moran were elected as corporators. Maria Bivona was promoted to branch manager at Academy of Information, Technology and Engineering High School. Diana Serrano earned three Connecticut Financial Training certificates and diplomas. Guilford Savings Bank Andrew Stephens joined as a mortgage originator. Brant Walker was promoted to senior vice president, wealth management. Renee Pallenberg was promoted to senior vice president, director of marketing & cash management. Shalonta Ford was promoted to vice president, retail banking officer. Michael DeBlieux was promoted to assistant vice president, loan operations manager. Lee Foo joined as vice president, cash management relationship officer. Rose Piro joined as a branch manager. Kristen Sibley was promoted to branch manager. Ion Bank Matthew Terribile joined as assistant vice president, branch manager. Laura Gallinoto was promoted to senior vice president, regional branch manager. Jane Pinho was promoted to vice president, business development. Mohammed Hassan joined 14

as AVP, branch manager. Kalim Jan was promoted to SVP, finance and investment officer. Christina Stone joined as assistant vice president, branch manager. Suzanne Hardy was promoted to senior vice president, controller. KeyBank Luciano Verdura joined as a senior relationship manager. Mark Commune joined as an area retail leader. Brandon Ojakian joined as an area retail lender. Carlos Salmon joined as a wealth advisor. Daryl Gordon was hired as a fiduciary strategist. Elissa Eddie transferred to Hartford as an area retail leader. Liberty Bank Chandler Howard was a guest on WTNH News 8's July 4 Connecticut Style supporting veterans and active military throughout the year and reminisced about his serving in the Vietnam War. Anne Fenton was promoted to assistant vice president, marketing communications assistant manager. Cari Small was promoted to vice president, Mansfield branch office. Danielle Pezzenti was promoted to assistant vice president, loan servicing manager. Wanda Perez was promoted as officer, resort finance team leader. Regina Keith was promoted to officer, commercial real estate team leader. Ornet Hines was hired as assistant vice president, Norwich branch

Fourth Quarter 2018 • Connecticut Banking Magazine

Mark Commune

Brandon Ojakian

Carlos Salmon

Daryl Gordon

Elissa Eddie

Chandler Howard

Anne Fenton

Cari Small

Danielle Pezzenti

Wanda Perez

Regina Keith

Ornet Hines

Chandler J. Howard

Jill Honeycomb

Martha Delisle

Don Mayland

Mickie Ann Budny

Sue Dickinson

Mark Gruttadauria

John Bailly

Michael Dawid

Michael Jordan

Rose Bronzino

Elizabeth Walker

Stephani Hayes

Jessica Guarman

Victor Lavoura

John Beir

Joseph Beale

Susan LeBel

John Scarritt

Charles Roraback

Vincent Camarota

Ray Giovanni

Dan Silva

Ozzy Obando

Brendan Theroux

Jaime Cowles

Karen Higgins-Carter

Tim Patneaude

manager. Chandler J. Howard received a “Local Leaders, Local Legends” Leadership Award from the Community Foundation of Middlesex County. Jill Honeycomb was named one of Bank Investment Consultant magazine's Top 25 Program Managers of 2018. Martha Delisle was promoted to officer, C&I/SBA team leader. Litchfield Bancorp Don Mayland celebrated his 40th year on the Board of Directors. Mickie Ann Budny and Sue Dickinson were promoted to vice president. Milford Bank Mark Gruttadauria was named vice president, business lending. John Bailly was named assistant treasurer and is a CT School of Finance and Management student. Michael Dawid joined as a controller. Newtown Savings Bank Karin O'Brien was promoted to vice president, BSA officer. Salisbury Bank & Trust Company Michael Jordan was promoted to vice

president, IT security and service solutions manager.

Roraback was appointed vice chairman of the board.

Savings Bank of Danbury Rose Bronzino joined as a mortgage originator. Elizabeth Walker joined as a branch manager in Stamford. Stephani Hayes completed a 3-year degree from the Stonier Graduate School for Bankers and a leadership certificate from the Wharton School. Jessica Guarman received an "Introduction to Human Resources" from CFT. Victor Lavoura graduated from Leadership Greater Waterbury.

Union Savings Bank Vincent Camarota joined as a financial advisor, wealth management. Ray Giovanni was re-elected as president of the Monroe Chamber of Commerce. Dan Silva graduated from the ABA's Stonier Graduate School of Banking and received the Wharton Leadership Certificate. Sarah Dziedcik was selected as a Leader Under 40 by the Northwest Chamber of Commerce.

Simsbury Bank John Beir joined as vice president, senior relationship manager. Joseph Beale lead a series of financial literacy sessions with the Simsbury High School Financial Literacy class. Susan LeBel graduated from the Center for Financial Training's Universal Banker Certificate program and received three specialty certificates. Torrington Savings Bank John Scarritt joined as vice president, commercial lending. Charles (Chip) 15

United Bank Ozzy Obando was promoted to vice president, commercial banker. Brendan Theroux was promoted to assistant vice president, commercial banking officer. Jaime Cowles taught a series of Junior Achievement classes to third graders in Enfield. Webster Bank, N.A. Karen Higgins-Carter joined as executive vice president and chief information officer. Tim Patneaude was promoted to executive vice president. u

Connecticut Banking Magazine â&#x20AC;˘ Fourth Quarter 2018

BANK OF AMERICA

BANKWELL

Bank of America partnered with the United Way and The Village for Families and Children to launch the Financial Resource Center in Hartford.

Bankwell donated $5,000 to the Norwalk Housing Foundation Scholarship Awards program and will sponsor the 20th Annual College Scholarship Awards Ceremony.

Bankwell renewed its commitment to the Ram Council Foundation with an $8,000 donation to the notfor-profit group.

Bank of America employees celebrated LGBT+ community at PrideFest 2018 in Hartford. Bankwell held a ribbon cutting at their new Darien branch.

Bank of America sponsored the Teen Innovation Program at the Connecticut Science Center, a summer internship program designed to mobilize high school students to engage in STEM.

Bank of Americaâ&#x20AC;&#x2122;s 2018 Student Leaders headed to Washington for the national summit for a paid summer internship and financial literacy training.

Bankwell held a ribbon cutting for its Westport branch.

BANKWELL

Bankwell had a new branch ribbon cutting in Stamford.

Bankwell Pet Adoption Program collected pet supplies and $2,500 to benefit local shelters and two members of the executive team added pets to their homes.

Bankwell was the title sponsor of the 2018 Wilton Farmer's Market.

Bankwell partnered with Spartan for the Bankwell Kids Spartan Race.

Bankwell was the sponsor of "The History of Westport in 100 Objects" exhibit at the Westport Historical Society.

CHELSEA GROTON BANK Chelsea Groton Bank secured a 5-star rating by Bauer Financial.

The Chelsea Groton Foundation awarded $189,585 in grants to 67 non-profit organizations.

Chelsea Groton introduced phone interpreter services to the community.

Fourth Quarter 2018 â&#x20AC;˘ Connecticut Banking Magazine

CHELSEA GROTON BANK

The Chelsea Groton Foundation presented scholarships to a select group of graduating seniors representing 19 area high schools.

FIRST COUNTY BANK

The Chelsea Groton Foundation presented a scholarship to a student at the Ella T. Grasso Southeastern Technical High School.

First County Bank announced three students received the $5,000 Richard E. Taber Citizenship Award scholarship.

DIME BANK The Dime Bank Foundation donated $3,500 to the Jonnycake Center of Westerly to help support their Emergency Food Assistance Program.

ESSEX SAVINGS BANK Essex Savings Bank Village Branch participated in a stocked backpack drive that resulted in over 70 backpacks for local youths.

Essex Savings Bank volunteered at the Connecticut River Museum's Annual RiverFare silent auction.

First County Bank participated as a Silver Sponsor for the Annual Hope in Motion Run & Walk raising funds for the Stamford Hospital Bennett Cancer Center.

GUILFORD SAVINGS BANK

Essex Savings Bank's total distributions to non-profits for the year will amount to $132,000.

The Guilford Savings Bank team took part in a biannual build for Habitat for Humanity in New Haven.

FIRST COUNTY BANK

ION BANK

First County Bank celebrated the 41st Anniversary Norwalk Seaport Association's Oyster Festival as the presenting sponsor.

First County Bank announced the recent winner of the FirstPrize $avings account $1,000 drawing.

First County Bank was the presenting sponsor for the Norwalk Summer Concert Series.

Ion Bank Foundation announced winners of its 9th Annual Community Awards Program at a ceremony awarding grants totaling $68,700 to 167 local non-profit organizations.

First County Bank was a sponsor of the 3rd Annual Weston-Westport Chamber of Commerce Dog Festival in Westport.

Ion Insurance Corporation held a ribbon cutting at their new Cheshire office.

Ion Insurance donated $670 to Jane Doe No More which was raised from their Quotes for A Cause program.

continued on next page

Connecticut Banking Magazine • Fourth Quarter 2018

JEWETT CITY SAVINGS BANK

KEYBANK

Jewett City Savings Bank had a local artist, Faith Satterfield, paint a sunflower mural on the back of the Jewett City ATM and is the first of many around town.

KeyBank was the presenting sponsor of Channel 3 Kids Camp's 2018 WRAP luncheon honoring Connecticut women for notable philanthropic contributions in their field and community.

KEYBANK

KeyBank presented a $5,000 grant to "Small Business in Key" contest winner.

KeyBank hosted its 28th annual Neighbors Make the Difference Day volunteering with 13 community organizations and service projects.

LIBERTY BANK KeyBank presented a $10,000 grant to the Nelson Hall Performing Arts Center at Elim Park in Cheshire.

Liberty Bank sponsored Operation Homefront’s Back-to-School Brigade in Groton where backpacks filled with school supplies were donated to military families.

Liberty Bank employees volunteered to help put finishing touches on Habitat for Humanity Greater New Haven homes.

Liberty Bank employees collected nearly 500 new toys for CT Children's Medical Center curing their annual Liberty Lends a Hand.

Liberty Bank hosted a Casual Friday for the Connecticut Chapter of the ALS Association, which raised $1,830 in the fight against Lou Gehrig’s disease.

KeyBank "up-and-coming" retail leaders completed the "Fast Track" program designed to give them the knowledge and leadership skills to achieve their career goals.

KeyBank served as a sponsor of the Connecticut Open tennis tournament.

Fourth Quarter 2018 • Connecticut Banking Magazine

LIBERTY BANK

Liberty Bank took part in the CT Humane Society‘s corporate engagement day.

Liberty Bank retail lending employees volunteered at The Connection, a leading private, nonprofit human service and community development agency that assists with behavioral health, family support and community justice programs.

LIBERTY BANK

Liberty Bank community development team and a colleague from Commercial Lending helped neaten up the grounds at the Connection House for Women in Middletown.

Liberty Bank operational risk management team used their strong arms and teamwork to help build a home for a military family in Portland with Middlesex Habitat for Humanity.

Liberty Bank Foundation’s annual Three Rivers Community College Scholarship presented several students with a $1,000 scholarship to further their college studies. Liberty Bank sponsored the Safe Haven of Greater Waterbury’s Golf Classic, this year held on August 7.

Liberty Bank employees in the Eastern part of Connecticut and from Technology pitched in and helped build the walls and foundation of a home for one family in the area while the Central South Market hosted their annual Greater New Haven Habitat for Humanity. Liberty Bank marketing employees put their magic wands and creative caps to use as volunteers for Journey Home in Hartford!

Liberty Bank was one of three banks in Connecticut to receive the designation of 2018 'Best Banks in America' by Forbes!

Liberty Bank was honored with the 2018 Financial Capability Innovation Award presented by the nation’s leading technology innovator, EVERFI, Inc.

Liberty Bank employees volunteered at Prudence Crandall Center in New Britain sprucing up the playground with flowers donated by Southington’s Winterberry Gardens.

Liberty Bank was the lead sponsor for both the Naugatuck and Shelton free summer concerts for families!

Liberty Bank held a Ribbon Cutting Ceremony for its new corporate headquarters.

Liberty Bank’s executive management team switched out their suits for red tees during Liberty Lends a Hand in June and hosted an annual BBQ for homeless veterans in New Haven.

Liberty Bank Foundation presented an annual $2,000 Adult Education Scholarship.

continued on next page

Connecticut Banking Magazine â&#x20AC;˘ Fourth Quarter 2018

LIBERTY BANK

Liberty Bank network support staff hosted a team in the Epilepsy Foundation of CTâ&#x20AC;&#x2122;s annual Mud Volleyball Tournament in August and was a corporate team sponsor.

Liberty Bank's annual Giving Circle program set aside $100 from each mortgage application in April and May and the Bank's Foundation spread the wealth to various Norwich nonprofit organizations.

SALISBURY BANK & TRUST COMPANY

Liberty Bank partnered with Save-A-Suit and WTNH News Channel 8 to collect suits, blazers, ties, shirts, women's itmes, dresses, and shoes for veterans returning home from active duty.

Liberty Bank employees volunteered for 900 hours at 18 different nonprofit agencies, collecting more than 13,200 donated items for over 60 organizations throughout the state.

Salisbury Bank & Trust Company hosted Community Day events with 12,360 pound of paper being shredded and recycled.

Salisbury Bank & Trust Company announced 10 scholarships in the amount of $2,500 to eligible students seeking a college degree in a variety of interests.

SAVINGS BANK OF DANBURY Savings Bank of Danbury opened a new branch on Summer Street in Stamford.

LITCHFIELD BANCORP Litchfield Bancorp sponsored their fourth local cash mob at G's Burgers.

Savings Bank of Danbury delivered 13 backpacks and school supplies to Park Avenue School in Danbury as well as $250 towards Kohl's gift cards.

Litchfield Bancorp hosted an open house at their Washington Depot location. Litchfield Bancorp donated $15,000 to the "From the Ground Up - A Campaign for Camp MOE".

SAVINGS INSTITUTE BANK & TRUST

Litchfield Bankcorp sponsored its third local cash mob at Empower Karate and Kickboxing.

Savings Institute Bank & Trust was honored at the Uniting for United Awards Ceremony for the most food collected for financial institutions and most dollars raised and highest amount of meals -- more than 6 tons of food and $8,500.

NORTHWEST COMMUNITY BANK Northwest Community Bank donated $2,500 to the Yale School of Music to support a classical music program for schools of the Region 7.

SIMSBURY BANK

PEOPLE'S UNITED BANK

Simsbury Bank hosted flu shot clinics with Farmington Valley VNA.

People's United Community Foundation awarded $332,000 in grants to nonprofit organizations in Connecticut.

SALISBURY BANK & TRUST COMPANY Salisbury Bank & Trust Company hosted a successful Community Day event with 6,140 pounds of paper shredded and recycled and non-perishable food and household items collected were donated to the food pantry in Canaan. Salisbury Bank & Trust Company offered a free seminar about upcoming changes to Medicare in 2019.

Simsbury Bank sponsored the Simsbury Police Cadet Programs with a $4,000 contribution.

Fourth Quarter 2018 • Connecticut Banking Magazine

START COMMUNITY BANK Start Community Bank was a sponsor of the FISH of Greater New Haven Gold FISH Gala. Start Community Bank was a tee sponsor and participated in Mighty Mia’s Golf Tournament. Start Community Bank was a tee sponsor of the Saint Martin de Porres Academy Golf Fore Kids. Start Community Bank was a sponsor and attended the Marcum Construction Summit 2018. Start Community Bank collected items for the Clifford Beers Annual Backpack Drive. Start Community Bank was a sponsor and attended the Spina Bifida Association’s Physical Freedom Festival.

Start Community Bank was a tee sponsor and participated in the GNHCC 25th Annual Scholarship Golf Classic. Start Community Bank was a sponsor of the Concepts for Adaptive Learning 2018 Murder Mystery Dinner Fundraiser.

THOMASTON SAVINGS BANK Thomaston Savings Bank was named the top in-state bank in Connecticut as well as the #1 bank in the country by Forbes.

TORRINGTON SAVINGS BANK

Start Community Bank was a sponsor of the New Light High School Student Scholarship. Start Community Bank was a sponsor of the New Haven Documentary Film Festival. Start Community Bank was a sponsor and participated in the 35th Annual Twohill Cup Golf Classic.

Torrington Saving Bank donated $100,000 to LARC - The Arc of Litchfield County.

UNION SAVINGS BANK

TD BANK, N.A.

The TD Charitable Foundation donated $10,000 to Rebuilding Together New Britain.

The TD Charitable Foundation donated $10,000 to Klingberg Family Centers.

Union Savings Bank Teachers’ Closet School Supply drive was launched in the month of August with collection boxes in all branch locations.

Union Savings Bank’s Canton Solutions Team visited Gifts of Love CT in Simsbury, CT and toured the farm during the last day of summer camp, exploring their educational programs."

The TD Charitable Foundation donated $10,000 to Child Guidance Center of Southern CT.

The TD Charitable Foundation donated $10,000 to Female Soldiers: Forgotten Heroes.

The TD Charitable Foundation donated $10,000 to Capital for Change.

Union Savings Bank was proud to support the Rotary Club of Danbury with the presentation of two Danbury High School Seniors with their respective $2,500 scholarships.

continued on next page 21

Connecticut Banking Magazine â&#x20AC;˘ Fourth Quarter 2018

UNION SAVINGS BANK

Union Savings Bank volunteers and runners participated in the 10th Annual Amber Room Colonnade Run from the Sun 5k in support of Ann's Place.

UNION SAVINGS BANK

Union Savings Bank hosted its 3rd Annual Share the Love of Reading Book Drive. Employees, customers and community members donated over 500 new and gently used children's books to share with their local communities.

Union Savings Bank leadership made the most of a recent corporate meeting by bringing much-needed summer donations of non-perishable food items. Over 600 pounds were shared with local food pantries.

Union Savings Bank collected over 500 professional attire items from employees, customers and the community to donate to Save-A-Suit an organization that prepares veterans as they re-enter the workforce.

Union Savings Bank was ready for whatever projects needed to be done during the United Way of Western Connecticut "Day of Action" and United Way of Northwest Connecticut "Day of Caring".

Union Savings Bank hosted their first Community Fair in two locations providing community partners an opportunity to showcase their services as well as provide employees with information on volunteer opportunities.

Union Savings Bank was honored to present six $1,000 scholarships to Danbury High School Seniors headed off to college in the Fall as part of the Brave Enough to Fail organization.

Union Savings Bankâ&#x20AC;&#x2122;s Canton Solutions Team participated in the 27th Annual Lobster Loop 5k Road Race which supports the Canton Middle School and their educational programs."

Fourth Quarter 2018 â&#x20AC;˘ Connecticut Banking Magazine

UNITED BANK

United Bank participated in Junior Achievement Day in Wallingford. The United Bank Foundation Connecticut donated $7,000 to the Interval House.

The United Bank Foundation presented a check to the Arts Center East for an upcoming exhibit in Vernon.

United Bank presented a $10,000 check to the Greenwich United Way.

United Bank cut the ribbon to its newest branches at CityPlace in Hartford.

WASHINGTON TRUST

Washington Trust was named to American Banker's list of top performing banks. Washington Trust rang the opening bell at Nasdaq on July 31.

WEBSTER BANK, N.A. Webster Bank donated $35,000 to the American Red Cross to support communities affected by Hurricane Florence and gas line explosions in Massachusetts' Merrimack Valley.

United Bank employees participated in a recent home build for Habitat for Humanity of Greater New Haven.

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