KENTUCKY BANKER October 2014
Key To Success Providing products designed specifically for community banks is key to becoming the best correspondent bank in the marketplace. Let The Bankers’ Bank of Kentucky offer your institution innovative solutions to meet the challenges of today’s complex banking environment.
• Daily Settlement & Cash Management • Federal Funds Lines of Credit • QNET correspondent connection • Loan Participations Buy/Sell • Holding Company Loans • Secondary Market Mortgage service • Safekeeping / Bond accounting • Asset liability management • ACH Origination • International Wire Transfer • Foreign Item Collection • Merchant Services • Visa Gift Card Program • IT Outsourcing* • And more!
Please contact a member of our Correspondent Banking Team at
800-248-3229
October 2014 | 2
for a personal appointment.
CONTAC TS BOARD OF DIRECTORS Mr. Bill Allen Bank of the Bluegrass and Trust Company
Ms. Elizabeth Griffin McCoy Planters Bank, Inc.
Mr. William Alverson Traditional Bank
Mr. Gordon Kidd United Cumberland Bank
Mr. James W. Beach Peoples Bank & Trust Company Owenton
Mr. Michael H. Mercer First Security Bank of Kentucky
Mr. William F. Brashear, II Hyden Citizens Bank
Mr. Glenn Meyers Kentucky Federal Savings & Loan Association
Mr. Neil S. Bryan The Farmers Bank of Miton Mr. David P. Heintzman Stock Yards Bank & Trust Company Ms. Lanie W. Gardner First National Bank of Muhlenberg county
Mr. Stephen Miller Peoples Bank of Kentucky, Inc.
Cover Photo taken by Alecia Marcum “Fall Colors�
Mr. Thomas J. Smith, III American Bank & Trust Company, Inc. Mr. Ryan Steger Commonwealth Bank FSB
for the Scenes of Kentucky Photo Contest
Mr. H. Lytle Thomas Heritage Bank Mr. Frank B. Wilson Wilson & Muir Bank & Trust company Mr. Greg A. Wilson The First Commonwealth Bank
Mr. Michael Mineer Citizens Deposit Bank & Trust Mr. Louis Prichard Kentucky Bank
KBA STAFF Ballard W. Cassady Jr. bcassady@kybanks.com President & CEO
Michelle Madison mmadison@kybanks.com Information Technology Manager
Debra K. Stamper dstamper@kybanks.com EVP / General Counsel / Director of Compliance
Lanie Minton lminton@kybanks.com Administrative Assistant
Paula B. Cravens Sturgeon pcravens@kybanks.com Director of Education Solutions Selina O. Parrish sparrish@kybanks.com Director of Vendor Solutions Matthew E. Vance mvance@kybanks.com Chief Financial Officer Miriam Cole mcole@kybanks.com Executive Assistant Paula Cross pcross@kybanks.com Education Services Coordinator Jamie Hampton jhampton@kybanks.com Education Services Coordinator Natalie Kaelin nkaelin@kybanks.com Assistant General Counsel
Tammy Nichols tnichols@kybanks.com Convention & Membership Services Coordinator Katie Rajchel krajchel@kybanks.com Staff Accountant Yvonne Savage ysavage@kybanks.com PAC Services Coordinator Angie White awhite@kybanks.com Manager, Communications Solutions Steve Whitlow swhitlow@kybanks.com Systems Engineer
Consultant
John P. Cooper jcooper@kybanks.com Legislative Solutions Consultant
KBA Insurance Solutions
KBA Benefit Solutions
Brandon Maggard bmaggard@kybanks.com Account Representative
Lane Hettich lhettich@kybanks.com Benefit Manager
Audrey Whitaker awhitaker@kybanks.com Insurance Services Coodinator
Donna McCartin dmccartin@kybanks.com Benefit Support Specialist
Tim Abbott tabbott@kybanks.com Account Representative
HOPE of Kentucky
Chuck Maggard cmaggard@kybanks.com President & CEO
Lisa Mattingly lmattingly@kybanks.com Director of Sales & Service
Billie Wade bwade@kybanks.com Executive Director
CONTRIBUTING EDITORS Lane Hettich lhettich@kybanks.com
Angie White awhite@kybanks.com
CONTACT 600 West Main Street Suite 400 Louisville, KY 40202
Phone: 502-582-2453 Fax: 502-584-6390 www.kybanks.com
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CHAIRMAN’S CORNER
H. Lytle Thomas
For many of us in community banking, the profession has our devotion. I am a banker today because, as a boy, I had the pleasure of spending a great deal of time with my grandfather…Lytle Moloney. He was President of the Farmers Liberty Bank of Augusta, Kentucky. I was always impressed that he knew so many people; and not that he knew just their names, but he knew their families, he knew their interests, he knew about their business and about the home they lived in or the farm they worked on. He cared about them and their success.
When the community needed help on a project, or advice on an issue, he was there to help. When the team needed a coach, or the school had a fundraiser, he was there. For him, life wasn’t just about the profits for the bank. He took pride in the success of the people and the community. I knew at a young age that I wanted to contribute to the world around me the way my grandfather did. Things have changed a bit since then. I can only imagine the look on my grandfather’s face if I had to show him the 14,000 pages of new regulations, Dodd Frank, compliance reports, the new CFPB bureaucracy, and additional regulatory burden yet to come. Despite all of these changes, we are still here. And our mission remains unchanged. As bankers, we are here to preserve the concept of “community banking.” We are here because the small towns throughout Kentucky need us, our employees, our clients, our schools, and our local businesses. We are a vital part of the economic well-being of our customers and our communities. A community cannot survive without a local bank to transact business.
The mission of the KBA is to work to make sure the environment for our Kentucky Banks remains positive for our institutions to succeed and prosper. As we know, the KBA serves as a centralized resource for not only government relations, but training, compliance, vendor relationships, best practices, and overall guidance. Since the banking crisis of 2008, compliance and regulations have grown at an alarming rate. Despite the fact that our banks were not the primary reason for this crisis. These regulations have had the unintended consequence of putting an enormous financial burden on our community banking industry, not to mention the stress and fatigue on the good people working in these community banks. The KBA works tirelessly to educate and challenge our federal, state, and local lawmakers to insure that new regulations will not be onerous or destroy the concept of community banking. When you speak to most legislators, senators, congressmen, and other elected officials, they love the concept of community banking. In spirit, most of them are 100% supportive of local community banking. Heck, most of them are customers of ours! Many times they simply don’t understand the unintended consequences of the regulations they pass. It is our job to ensure that every elected official understands the consequences of every single piece of regulatory legislation. I am truly honored to serve as the Chairman of the KBA. I pledge to fight on our behalf to keep the regulatory environment in check for our industry. And I pledge that together, with the KBA, we will provide meaningful resources for each and every one of your institutions. As Henry Ford once said – “If everyone is moving forward together, then success takes care of itself.”
Together we will be successful!
Proudly Serving KentucKy BanKS for 25 yearS t ax -f ree /t axaBle M uniciPal B ondS • uS t reaSurieS /a gencieS
Bill Barker Toll Free: 800.292.4563 bbarker@rsanet.com
One Riverfront Plaza • 401 W Main St, Suite 2110 • Louisville, KY 40202
Louisville ~ Lexington ~ Cincinnati -KBa a SSociate M eMBer Member FINRA and SIPC • Investment Products Not FDIC Insured • No Bank Guarantee • May lose value.
October 2014 | 4
A community bank’s greatest ally for over years.
100
First Tennessee Correspondent Services offers a range of robust financial and business solutions to support community banks. When you work with First Tennessee, you’ll get the personal attention that’s made us a continuous provider of correspondent services for over 100 of our 150 years in business. First Tennessee Correspondent Services include:
Holding Company Loans | Image Cash Letter | Letters of Credit | Settlement Services Treasury Management | International Services | Fed Funds | Safekeeping
TALK TO A RELATIONSHIP MANAGER ABOUT YOUR BANK’S NEEDS. CALL 800-453-7686 OR EMAIL CORRESPONDENTSERVICES@FTB.COM © 2014 First Tennessee Bank National Association. Member FDIC.
October 2014 | 5
STRAIGHT TALK Political Correctness to a Fault \
my sliver of seat left much to be desired since both “A” and “C” required additional room. Since when is being “PC” to one customer and not forcing them to buy an additional seat for their “abundance” fair for the other customer, who spent the same amount of money, but is essentially “out of luck?” Furthermore, airline seats are only 17.2 inches wide on average (just for future reference).
When did running from issues become the norm? Political Correctness (PC) has put a dagger through the heart of discussion and trampled on one of the most important American freedoms...freedom of speech. I don’t understand it. We tell our children not to lie, to express themselves, and to communicate their ideas... especially if they differ from “the group.” We stress individuality, yet in Washington we maintain a delusional façade of appropriateness and conformity that essentially white washes the issues at hand. At what point did we grow out of personal expression and adopt PC- is it societal, taught at home, or learned in the workplace as we operate with various personalities, ages, and demeanors? Remember the 60’s? Everyone knew exactly where you stood on the social issues. Either you supported the war or you didn’t- you weren’t ashamed of your opinion because it was YOUR OPINION. And we talked to each other about why we held different opinions. It seems our media shies away from rational discussion and focuses instead on the politically correct response. If any smart journalists remain who studied the Socratic method, they would look at both sides of the argument before delivering the facts (but facts aren’t always PC). Last time I flew, I booked at the last minute, and found myself relegated to the dreaded middle seat. To my chagrin, the “A” and “C” seats were already full and
Look to the ball fields for another example of PC trumping common sense. A family friend has small grandchildren who play soccer. Each and every child, no matter what type of sportsmanship they possess (or talent for that matter) receives a trophy. In my youth, trophies were given to the winners, or perhaps the top three. What sort of adults are we creating if life is only built on success and everyone wins? What happens when they get a C in high school? Reality is not PC- everyone does not win. Those who work hard have a better chance of victory than those who slide by. Real, honest conversations need to take place. Conversations about our government, immigration, racial issues, healthcare for those who cannot afford it, and the price of an education. These are nitty-gritty talks that can and will offend people—perhaps they should! Too often we succumb to the “talking heads” on the news and fail to verbalize our own opinions out of fear of not being PC. Political correctness mitigates the real conversations that need to take place.
never get any closer to solving the world’s problems. American author Vince Flynn said it best, “It’s this upside-down world that we live in where we afford political correctness to the most intolerant group of individuals on the planet.” At some point our country’s own interests must come into play and we must address the issues that will impact our future and our children’s future. I challenge you...for one day, stop being PC. Tell it like it is, be truthful and honest in your delivery, and genuine with your criticisms and praise. Live by the golden rule and operate your business and personal life the way your mother taught you - HONESTLY.
For example- I don’t know the best way to pursue ISIS, but I do know our legislators need to talk about the number of soldiers this terrorist group has killed, the number of civilians who have lost their homes, and the number of struggling families affected by this organization. Ambiguous, airy conversations must end, or they will put an end to our government. If you’re not willing to call a spade a spade, turn in your media license and don’t play the game. PC is clouding our perception of right and wrong. I acknowledge that gray area exists in many of the struggles we face today- but unless we support discourse and shed light on the gray area, we
Let me know what you think: bcassady@kybanks.com October 2014 | 6
STRAIGHT TALK Ohio Valley Bancorp & Financial Services Holding Corp. Anncounce Merger Henderson-based Ohio Valley Bancorp, Inc. (“Ohio Valley”), parent of Ohio Valley Financial Group ($258 million in assets as of March 31, 2014) and Henderson-based Financial Services Holding Corporation (“FSHC”), parent of BankTrust Financial Corp. ($130 million in assets) today jointly announced signing a definitive merger agreement in a stock-for-stock transaction. Upon completion, the new Company will rebrand itself and proposes to operate under the new name Field & Main Bank. Legacy Ohio Valley shareholders will own approximately 69% of the combined company, while legacy FSHC shareholders will own approximately 31%. Upon completion of the merger, the combined organization is projected to have approximately $400 million in combined assets, $315 million in gross loans, and $34 million in tangible common equity.
dous opportunities to build on the successes that each company has achieved," said Dale Sights. “We are uniting two strong, profitable, and well capitalized community banks. Together, we will be well positioned to generate significant growth and to serve all of the financial needs of the community with greater competitive strength, growth potential and profitability.”
The leadership team of the new bank will be led by Scott Davis, Chairman and CEO of Ohio Valley, Chris Melton, President of Ohio Valley, and Dale Sights, President and CEO of BankTrust. Additionally, each board member of Ohio Valley and FSHC is expected to join the board of the new company. Longer term, the company will adjust the size and representation to an appropriate level for a pro forma institution of its size. “This merger creates tremen-
The transaction is expected to close during the fourth quarter of 2014, pending regulatory approvals and is subject to customary closing conditions. Upon closing of the transaction, on a pro forma basis, the combined company is expected to maintain regulatory capital ratios in excess of requirements.
Scott Davis added, “We believe that this merger will create value for the shareholders, customers and employees of both organizations by combining two cultures that reflect a tradition of superior customer service at all levels. We are excited about the growth prospects for our combined financial institutions, which are enhanced by a strong capital base, an increased lending capacity, and an expanded branch network.”
Central Bank in Northern KY Hosts Lunch with Mitch McConnell
From left to right: Merwin Grayson, President of Central Bank Northern KY, Senator Mitch McConnell, Lytle Thomas, President/CEO Heritage Bank and current KBA Chairman, Ballard Cassady Jr., President / CEO of KBA
October 2014 | 7
October 2014 | 8
Q: Do we have to notify the Kentucky Department of Financial Institutions to open a Loan Production Office (“LPO”)? A: Kentucky statute KRS 286.3-820 (2) states a bank, except for a bank that the commissioner may designate by the promulgation of administrative regulations, shall apply to the commissioner for permission to establish a loan production office. So, in general, to open an LPO a bank must request permission from the commissioner UNLESS the bank meets the criteria set out by the commissioner in the administrative regulations. The pertinent administrative regulation is 808 KAR 1:150 Section 2: The following criteria shall be satisfied before a bank may undertake the activities described in Section 1 of this administrative regulation without executive director approval: (1) The bank shall have received its bank charter at least three (3) years prior to undertaking the activities; (2) The bank shall be well-capitalized: (a) As defined in 12 C.F.R. Part 325 by the Federal Deposit Insurance Corporation, if the bank is a nonmember bank; or (b) As defined in 12 C.F.R. 208.43(b)(1) by the Federal
Reserve Board of Governors, if the bank is a member bank of the Federal Reserve System; (3) The bank shall have received a CAMEL composite rating of one (1) or two (2) on its most recent state or federal regulatory examination; (4) The bank shall have received a management rating of one (1) or two (2) on its most recent state or federal regulatory examination; (5) The bank shall not be a party to any formal or informal enforcement action initiated by a state or federal regulatory agency; and (6) The bank’s activity shall not cause the bank to exceed the fixed asset limitation established in KRS 286.3-100. Required notices and other information can be found in the administrative regulation found at the following link: http://www.lrc.ky.gov/kar/808/001/150.htm
Recruiting A successful investment program offers a community bank many advantages: attracting and retaining customers, competing with national banks and brokerage firms, credibility in the community and non-interest income opportunities. One of the biggest deterrents to banks, however, is how to identify and attract the right advisor to meet the financial needs of your customers. As you might imagine, hiring the right rep is arguably the single most important factor in determining the success of a program. Most agree that the best approach is to recruit an experienced, successful advisor from within your community. The advantages of hiring an experienced rep are significant: • The success rate is low in the brokerage industry (only one rep in eight remains in the industry after their first two years), so hiring an experienced advisor only increases the odds of success. • Existing advisors typically bring some of their client base with them, providing potential new customers to the bank, as well as an almost-instant revenue stream. • An experienced rep has already established skills in assisting clients with their financial needs, greatly reducing the likelihood of learning the business at the expense of your customers. But why would an already successful advisor leave their current firm to work for a community bank? Not surprisingly, a bank offers many advantages to a rep. Credibility and goodwill are the biggest advantages a rep inherits through a relationship with the bank. While some investment firms maintain a positive reputation, few approach the credibility community banks have earned from their customers. An advisor representing your bank will be able to leverage this goodwill to get in front of more prospects than they otherwise would as a repre-
sentative of a brokerage firm, allowing them to build their practice much more efficiently. The opportunity for referrals is also an obvious benefit to a candidate. Advisors working outside of banks receive no referrals directly from their firm – in fact, those working in large offices actually compete against their fellow employees for customers, rather than relying upon them for referrals. In most cases, a community bank offers an improved entrepreneurial environment for building a business. Many of the conflicts that exist among pure brokerage firms are non-existent within a community bank: pressure to sell more profitable products, everchanging sales quotas, negative press, revolving branch managers and changes to compensation packages are just a few of the frustrations advisors in our industry experience on a regular basis. In the early years, bank brokerage was saddled with the reputation of second-rate status to the major brokerage firms – a place for reps that couldn’t make it with the Wall Street firms. As the broker dealers working with banks evolved to offer the same products, services, and technology available at the largest national firms, the perception shifted and many advisors left for the advantages of a community bank, recognizing that there is no quicker way to build a practice. A bank’s broker dealer partner should be an invaluable resource when it comes to choosing the individual that will staff your program. To learn how to leverage IPI’s 22 years of bank brokerage experience to help build a program for your bank contact Vince Bailey at 210.542.8508.
October 2014 | 9
CyberSecurity: Where to Begin? The financial sector is regularly targeted by cyber-criminals as noted by the 2014 Verizon Data Breach Investigations Report which revealed that the financial sector was the most targeted in terms of 2013 incidents. The recent cyber-attack of J.P. Morgan Chase is just one example, but serves as another reminder that the financial sector faces daily attacks and must stay vigilant.
the data stored? How is the data accessed? These are the questions that must be answered before you can determine how to protect the data. For community banks, customer information might be primarily housed at a third-party vendor, but how do you ensure access is properly secured? Even though your data is stored externally, what might still be housed on your local systems?
The Federal Financial Institutions Examination Council’s (FFIEC) pilot program, Cybersecurity Assessment, was designed to assess community institutions’ vulnerability and preparedness to cyber threats. While the Cybersecurity Assessment aids the FFIEC agencies in identifying and prioritizing actions to enMCM’s Financial Institutions Services Team strives to help banks succeed by hance supervisory programs, assessing and managing the risks associated with vendor management. By guidance and training, finanidentifying and managing risk throughout the vendor life cycle, from planning, cial institutions can also take due diligence and selection, to oversight and accountability, we help ensure that steps to strengthen their own your third-party relationships add value and encourage confidence in your board preparedness.
Meaningful relationships, beyond the bottom line. and regulatory agencies.
Cyber Security Framework The National Institute of Standards and Technology (NIST) Cybersecurity Framework can aid in strengthening your institution’s cybersecurity program. The framework is not a complete checklist, but it is a useful tool to help with developing a cybersecurity program to fit your risks and business needs.
Contact our industry leader to learn more. Henry Hawkins, CPA, Financial Institutions Services Director 502.882.4490, Henry.Hawkins@mcmcpa.com
mcmcpa.com | Indiana | Kentucky | Ohio
While the thought of the Cybersecurity Framework might seem new and overwhelming, the functions and category outcomes should be familiar. Financial institutions should already be developing similar framework as part of the Information Security Program requirements. The Cybersecurity Framework core discusses five functions, each with its own set of outcome categories:
Expert guidance, beyond the bottom line.
Baseline Security Controls Establishing baseline security controls are your foundation at protecting your systems. When determining how secure your internal systems are, start by answering a few questions: What are your defined password policies? What are your audit log policies? What are your firewall rules? Do you know the vulnerabilities in your systems?
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Identify - asset assessment, governance, risk assessment and risk management strategy
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Protect - access control, awareness, training, data security and protective technology
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Detect - security monitoring and detection processes
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Respond - response planning and communications
How do you monitor changes in your systems? Changes to security controls should not be ad-hoc, but based on a defined approval process. In addition, changes should be proactively monitored to ensure that they are approved and align with baseline settings. Periodic vulnerability assessments are necessary to ensure that security controls are sufficient in the ever changing environment. MCM will be happy to assist in the evaluation of information security programs and other IT general control reviews.
•
Recover - recovery planning and improvements to restore the capabilities of what was impaired
Contact MCM’s Financial Institution Services Team for more information.
Data Asset Inventory The critical building block in tackling cybersecurity is the performance of the data asset inventory, including data classification. What is your data? How critical and sensitive is the data? Where is
October 2014 | 10
Michele Welscher, CPA/CITP, CIA, CISA Michele.Welscher@mcmcpa.com, 502.882.4484 Rick Taylor, CISA Rick.Taylor@mcmcpa.com, 502.882.4495
UPCOMING EDUCATION EVENTS & SEMINARS
Asset Liability Management Seminar (IRR Management & Investment Strategies) October 8 Louisville Tricks of the Trade - Collection Strategies, Workouts and Judgment Remedies Seminar October 9 Louisville FDIC Community Bankers College October 21 Bowling Green October 22 Lexington ESSENTIALS OF BANKING SCHOOL November 3-7 Louisville Personal Safety Seminar Run, Hide, Fight, or Comply? October 28 Paducah October 29 Bowling Green November 5 Florence November 11 London
November 12 Lexington November 13 Grayson Cash Flow Seminar November 12 Bowling Green November 13 Lexington Ag Lending Seminar December 2 Bowling Green IRA Administration Pegasus Seminar December 2 Paintsville December 3 Somerset December 4 Paducah December 9 Elizabethtown December 11 Lexington December 16 Bowling Green
Coming in 2015…. Appraisals and Evaluations Compliance Review Seminar: An In-depth Study January 21 Lexington January 22 Bowling Green How to Improve Your Collection Department Seminar January 28 Louisville Consumer Lending School (Two Day Program) March 24 & 25 Bowling Green March 26 & 27 Lexington
Safe Deposit Seminar December 3 Bowling Green December 4 Lexington
Training Tidbits The ABA Supervisor Certificate trains your new and potential Supervisors for their emerging responsibilities with courses that offer fresh insights on proven managerial approaches. You must complete the following courses: •*Banking Today (*Principles of Banking may be substituted)
•Coaching for Success
•Corrective Action
•Ethical Issues for Bankers
•Hiring the Best
•Leveraging the Benefits of a Diverse Workforce
•Managing Change
•Managing Employee Performance
•Managing Employee Relations
•Rewards and Recognition
The estimated time to complete these 10 online self-paced courses is approximately 19 hours. Students have access to the curriculum for 1 year from date of purchase. Register for all courses as a bundle and you will receive the packaged price of $595. For additional information email Jamie Hampton jhampton@kybanks.com
tHis is An ADveRtiseMent.
congratulations! Remarkable people make all the difference. Thank you for all that you do.
Mindy sunderland Business First of louisville Forty under 40 Honoree
celebrating 40 years of legal service in the banking industry.
MorganandPottinger.com
LouisviLLe
Lexington
neW ALBAnY
United Citizens Bank & Trust Co. On August 20th, United Citizens Bank & Trust Co., Inc. celebrated the grand opening of their newest branch location at 5364 South Main Street in Eminence. Left to Right – Zac Banta, Sandy Phillips, Linda Briley, Tabby O’Nan, Terry Lucas, Joyce Hall, Cassie Emily
New Resolutions Process We value our bankers and their lifelong commitment to the communities in which they work. Many banks publish resolutions for bankers they wish to honor. Going forward, the Kentucky Banker Magazine will feature a special biannual Resolutions Issue. If you do not wish to feature your resolutions in the issue, we will happily send a certificate of recognition for publication in the local newpaper of your choice. We appreciate all our bankers and look for opportuninites to honor them publicly in the communities they serve. If you have questions, please contact Angie White at awhite@kybanks.com
October 2014 | 12
Potential Issues Facing Lending Institutions When Extending Credit to Non-U.S. Citizens Christopher B. Markus and Aaron E. Caskey American lending institutions are often faced with requests from non-U.S. citizens for loans in connection with various financial transactions. Therefore bank employees should be aware of the potential legal ramifications that accompany the extension of credit to non-citizens and the potential recourse available should a default occur. This article examines some of the legal considerations that financial institutions should be aware of before engaging in such transactions. One issue is whether it is permissible for a lending institution to legally deny a non-U.S. citizen a loan because of their nationality under the federal Equal Credit Opportunity Act. Regulation B of this Act prohibits creditors from discriminating based on race and national origin in determining whether to loan funds. However, financial institutions may consider several factors in determining whether to extend credit to non-U.S. citizens. These include: (1) immigration status and ties to the community; (2) whether the individual is a resident of the United States; and (3) information concerning the lender’s ability to collect payments. In addition to the potential issues arising out of a decision not to lend to an individual because of their citizenship status under Regulation B, many states have adopted civil rights legislation that further prohibits such conduct. But there has not been a lot of litigation on this issue and the few cases that have been advanced on each of these theories have been dismissed. However, bank employees should be aware of the potential threat of litigation as a result of these laws. Another issue arises in the context of the Patriot Act. Under the Act, financial institutions are responsible for forming a reasonable belief of the true identity of each customer prior to opening a credit account with the individual. At a minimum, the bank must obtain the name, date of birth, address and identification number of each individual seeking to obtain credit. After this information is obtained from the customer, the lender must employ verification techniques to ensure compliance with the Patriot Act. These verification techniques contemplate the use of documentary and non-documentary sources. Verification through documents includes obtaining government-issued identification papers (e.g., birth certificate, driver’s license or passport). However, verification through such documentation may always be possible for non-U.S. citizens. In such cases, financial institutions may resort to verification through non-documentary methods. Such verification may include (1) contacting the customer; (2) obtaining credit reports from foreign jurisdictions; or (3) obtaining credit references. Regulations enacted pursuant to the Patriot Act also impose a duty on lending institutions to ensure that funds are not being utilized in efforts that are contrary to United States national security. Thus institutions are required to check the Office of Foreign Assets Control list for all loan applicants to ensure it is legally permissible to continue with the loan process with the non-U.S. citizen
assets. However, the jurisdiction of the United States judicial system is not without limitation. And a foreign jurisdiction is not necessarily required to honor any ruling made by a United States court. As a result, it can be difficult for lending institutions to obtain recourse for unpaid debts when a borrower’s assets are not located within the United States. Therefore, lending institutions extending credit to such individuals should consider protective mechanisms in the event of default. By way of example, these include (1) ensuring the borrower has pledged sufficient assets within the United States to secure the debt; or (2) requiring an American citizen to co-sign the note and accept liability in the event recourse against the non-U.S. citizen is not easily available. In summary, there are many complex legal issues that arise when lending institutions extend credit to non-U.S. citizens. This article, though not to be considered an exhaustive list, highlights just a few of those issues.
Mr. Markus is an associate at the law firm of Dressman Benzinger LaVelle psc whose practice focuses on banking and commercial litigation Mr. Caskey works as a law clerk at Dressman Benzinger LaVelle psc. He graduated, summa cum laude, from the University of Kentucky College of Law in May 2014, sat for the Ohio bar examination in July 2014 and will sit for the Kentucky bar examination in February 2015.
Yet another potential issue concerns the recourse a lending institution has in the event of default. Typically, a court-ordered judgment permits a creditor to seek recourse for unpaid loan debt through liquidation of the judgment debtor’s non-exempt October 2014 | 13
How Does a Charged-off Checking Account Become a Minefield of Issues? Darlia Fogarty, Director of Compliance, Compliance Alliance
We’ve recently been made aware of a process that quite a few banks have been doing for many years that could very easily cause the bank many issues with the regulatory agencies. Here is the scenario — banks have made it a policy to add the balance of a charged-off deposit account to the principal of a loan the customer has at the bank. This policy presents a minefield of issues that must be addressed, including contractual language, UDAAP, safety and soundness and compliance issues (disclosures). This memo highlights some of the issues presented by this policy in light of the continued regulatory focus on overdraft programs. Just a few of the issues presented, by adopting this practice, in light of the continued regulatory focus on overdraft programs are: 1. With respect to overdrafts, banks need to follow GAAP and the Call Report guidelines and should be reporting these chargedoff accounts as such. This, in a nutshell, means that these losses come out of the bank’s bottom line income. In an issuance from 2005, the FFIEC requires that an overdraft be charged off against current year’s income when the account is overdrawn for 60 days, as stated in the FFIEC guidance on overdrafts. Paying off an overdraft by adding principal to an existing loan effectively sidesteps the rule and masks the loss of income. This presents a safety and soundness issue because the bank may be over reporting income because the loss will no longer be reflected on the books. In essence, you are capitalizing a past due loan and calling it income. Additionally, the existing loan that has had the overdraft tacked onto the principal balance could well be considered as impaired since now the borrower has demonstrated that they do not have the ability to remain current on their debt obligations. 2. Whether this practice is even permissible would be governed by the agreement between the borrower and the lender. Since each loan is unique, the bank will have to consult their counsel to determine their rights and remedies with respect to the specific loan. Often, banks assume that there is a provision in the loan agreement permitting this. Rather than assuming, the bank should carefully read the loan agreement to determine if this is accurate. Keep in mind, this action would not be considered in the same category as force placement of insurance. 3. There is also a question of whether disclosures are necessary under Reg Z prior to converting the balance of the overdraft to a loan that accrues interest. As a reminder, Reg Z and Reg DD, of course, would only apply to consumer loans/accounts. With that being said, any fee for overdrafting an account must be disclosed per Reg DD. The official commentary to Reg DD provides: (5) Fees for overdrawing an account. Under §1030.4(b)(4) of this part, banks must disclose the conditions under which a fee may be imposed. In satisfying this requirement, banks must specify the categories of transactions for which an overdraft fee may be imposed. An exhaustive list of transactions is not required. It is sufficient for an institution to state that the fee applies to overdrafts “created by check, in-person withdrawal, ATM withdrawal October 2014 | 14
or other electronic means”, as applicable. Disclosing a fee “for overdraft items” would not be sufficient. Any interest accrued by virtue of adding the amount to the principal of a loan, would likely be considered a “fee” for the overdraft that must be disclosed at account opening. Unless the bank disclosed the fact that an overdraft may incur interest charges, you would be in violation of Reg DD. Even if the possibility were disclosed on Reg DD, the program would then be a de facto overdraft line of credit. As such, you would likely need to provide Reg Z disclosures for open-end lines of credit. 4. There is also a significant UDAAP concern with the practice of adding an overdraft balance to the remaining principal of an existing loan converting the overdraft balance to a loan that accrues interest. Under Dodd-Frank, an act or practice is unfair when: •
It causes or is likely to cause substantial injury to consumers;
•
The injury is not reasonably avoidable by consumers; and
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The injury is not outweighed by countervailing benefits to consumers or to competition
First, while there is no specific definition of “substantial injury,” it typically means that monetary harm has been sustained. In this case, the customer is being charged interest on a loan whereas before they were not. Second, the bank may say that the injury is “avoidable,” but regulators will not likely see it that way. In any case, it may not be “reasonably” avoidable, especially if the customer does not have the means of paying it off. Finally, the third test of the unfair analysis is to prove this is beneficial for the consumer. It would be difficult to think of any situation where a consumer is better off for having to pay interest. Even if it is not “unfair,” a regulator may still find a UDAAP violation, as the practice can be abusive or even deceptive depending on how the program is administered. In any case, the bank is opening itself up for increased scrutiny for UDAAP. While there is no conclusive guidance on the practice of capitalizing an overdraft balance into an existing loan, the practice presents many issues that need to be addressed. During regulatory panels, regulators have said this is a practice that would cause “great concern” and we are aware of at least one bank that has had issues with regulators suggesting that this practice violates UDAAP. Even though this practice may have been going on for some time, banks need to re-evaluate the program in light of the tighter regulatory environment Dodd-Frank has created.
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Shedding Light on the Farm Credit System, America’s Least Known GSE FCS uses 100-year-old arguments to defend its existence Ken Auer, president of the Farm Credit Council, the FCS trade association, recently wrote to Rep. Rick Crawford, chairman of the House Agriculture Committee’s Livestock, Rural Development, and Credit Subcommittee, which is charged with FCS oversight. Essentially, Auer’s letter was a futile attempt to defend the indefensible – the many tax, financial, and regulatory advantages the FCS has over banks and other tax-paying competitors. Auer’s letter was triggered by a June 25 hearing Rep. Crawford held on credit availability in rural America. Here is a link to Auer’s letter. Auer’s letter, and indeed the entire rationale for today’s FCS, is based on the false premise that Auer asserted at the end of his letter: “The credit needs in rural America are greater than either the commercial banks or the [FCS] can alone finance.” While it is certainly true that the FCS lacks the financial capacity and infrastructure to meet all of rural America’s credit needs, America’s commercial banks, other private-sector lenders, and the capital markets can certainly meet all of those credit needs. Worse, the overlay of FCS institutions on a network of banks and other private-sector lenders adds to the total cost of providing credit in rural America. Rural America would be economically stronger without the FCS, and all taxpayers would benefit as a result. The following is a highly summarized rebuttal of the seven assertions in Auer’s letter: FCS’s Mission is to Be Agriculture’s and Rural America’s CustomerOwned Partner Agriculture and rural America, like all of America, is best served by financial firms competing on a level playing field, specifically with regard to taxes and funding, regardless of whether they are owned by stockholders or their borrowers. Stockholder-owned banks, as suppliers of credit, are just as much partners with the farmers and other rural businesses who borrow from them as are FCS lenders, who are supposed to be just as rigorous as banks in judging and pricing credit risk. Likewise, FCS institutions are as focused on earning an adequate return on their capital as banks, but with a difference – FCS institutions, as a practical matter, are not subject to the external market discipline that banks are. As has been demonstrated repeatedly, FCS institutions are run by incumbent management and pliant boards of directors with no real accountability to their borrower/stockholders. FCS’s lack of accountability is reinforced by its captured regulator, the Farm Credit Administration (FCA). Farm Credit Associations Have a Great Record of Serving YBS Farmers As numerous issues of the FCW have demonstrated with FCS lending data, including last month’s FCW, not only has the FCS become increasingly focused on lending to larger farmers and agribusi-
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nesses, but much of what it characterizes as lending to young, beginning, and small (YBS) farmers in fact is lending to consumers ineligible to borrow from the FCS. The fiction that FCS is an aggressive lender to YBS farmers is enhanced by FCA regulations that allow double- and triple-counting of YBS loans that often do not go to YBS farmers. Every Financial Institution Must Have a Liquidity Line Auer attempted to justify the secretive manner in which FCS negotiated a $10 billion line-of-credit with the Treasury Department last year by stating that it is the only GSE “that does not have a direct statutory backup line of credit with the Treasury.” [emphasis supplied] Auer claimed that obtaining a line-of-credit “needed no Congressional action,” yet Congress authorized all other GSE lines-ofcredit with the Treasury as well as the FDIC’s line-of-credit. The simple fact is that FCS did not want to risk asking Congress because that would have given Congress a chance to rein in the FCS’s increasingly evident violations of the lending restrictions previously imposed on the FCS. I also should note that while the line-of-credit was being negotiated, CoBank was making its $750 million loan to Verizon. Commercial Banks are Subsidized and Backed by Taxpayers – FCS Brings the Benefit of its GSE status to Agriculture and Rural America, While Not Operating at Taxpayer Expense All bankers know that commercial banks are not backed by the taxpayers, as the FDIC is funded entirely through deposit insurance premiums banks pay while banks pay taxes on all their profits, either at the bank level or at the shareholder level since bank dividends, including those paid by Subchapter S banks, are fully taxable. The FCS enjoys two explicit taxpayer subsidies – first, an exemption from all income taxes on profits from its real-estate lending and an exemption from state income taxes on profits on non-real-estate lending by its Agricultural Credit Associations. Second, the FCS’s ability to borrow cheaply as a GSE reflects the financial markets’ assurance that the FCS is taxpayer-backed, a belief reinforced by the $10 billion Treasury line-of-credit. FCS Lending Improves Credit Availability in Rural America Commercial banks and other taxpaying lenders offer every type of financial product the FCS does – the FCS does nothing unique in rural America except provide taxpayer-subsidized credit to large corporate farmers, agribusinesses, and companies such as Verizon. The FCS could become a private-sector, taxpaying entity without a negative impact on credit availability or cost in rural America. “Similar Entity” Lending Helps FCS Partner with Commercial Banks Auer tried hard to press the ridiculous claim that Verizon was just a
“similar entity” to a small rural telephone cooperative. How he did that with a straight face escapes me. Commercial banks and other taxpaying lenders do not need to “partner” with the FCS in order to meet all of rural America’s credit needs. In fact, private-sector lenders have sufficient deposits and capital market access to meet rural America’s credit needs, on and off the farm. Further, banks and other taxpaying lenders have sufficient technology and on-theground lending infrastructure to deliver that credit. Interestingly, Auer did not attempt to justify the FCS’s participation in the Verizon and Frontier Communication loans. Likewise, CoBank’s recent syndication of a $650 million loan for Farmland Industries could just as easily have been handled by a large commercial bank. CoBank did not provide a unique service to Farmland. Focus of Financial Institutions Should be on Improving Rural Economy
All lenders operating in rural America will benefit from an improving rural economy, which is why banks, especially community banks serving rural areas, continually seek to provide credit to farmers and rural businesses. The FCS is no longer needed to meet those credit needs and taxpayers can no longer afford the FCS’s annual $2 billion tax and credit-cost subsidy. Report FCS lending abuses to: green-acres@ely-co.com Bankers are continuing to send FCW reports of FCS lending abuses, such as FCS loans for rural estates, weekend getaways, and hunting preserves. Email reports of similar lending abuses in your market to: green-acres@ely-co.com. Please provide as much detail as possible about any loan which violates the spirit, if not the law, governing FCS lending.
Kentucky Bank Upgrades Showalter Office Kentucky Bank has two banking offices in Georgetown, one at 260 Blossom Park Drive and the other at 103 W. Showalter Drive. The Showalter office has just finished going through the first major remodeling since it was built in 1998. Along with new banking technology, including mobile and online banking, customer’s needs for branch offices have changed. With that in mind, Kentucky Bank has created a branch for the entire family.
Kentucky Bank has been recognized as one of the top 200 community banks nationwide and one of the "Best Places to Work in Kentucky” for three consecutive years. Kentucky Bank’s historic strength and stability offer their customers invaluable peace of mind. Kentucky Bank has fifteen locations in ten Kentucky Counties. Kentucky Bancshares, Inc. is traded under the symbol, KTYB. Visit Kentucky Bank online at www.kybank.com.
The Showalter office is in a residential area, but conveniently located between the Post Office and the Scott County Library. Mark Sulski, Market President, described the remodeled office, “We wanted this office to feature a more user friendly, family approach. The entire branch has been remodeled and upgraded with a contemporary atmosphere. The branch has Wi-Fi and a table with iPads for customer use; this allows us to show our customers how easy it is to connect with our mobile and iPad banking apps. Customers are also welcome to check email and access the web with the iPads. “ The office has been upgraded to make the customer experience easier and more enjoyable. One wall features a “kid’s wall,” where children can enjoy interactive activities while their parents are doing their banking. The bank has lowered the counters to allow customers and bank representatives to talk and do transactions in a more convenient manner. The sitting area features a self-serve Keurig coffee machine and bottled water for customers. This office is a great blend of convenience with technology and family space. The office has a conference room, which is used primarily for closing mortgage, personal, business and agriculture loans. The lenders at this office are very active in the Scott County Market. The Showalter office is fully staffed: Mara Maybury, AVP Mortgage Loan and Small Business Officer; A J Gullett, Small Business Administration and Guaranty Officer; Megan Melton, Retail Banker; Laura Bolen, Head Teller. Tellers Stephannie Franklin, Sara Wilson, and Judy Swallow are all located in the Showalter office. Kentucky Bank welcomes people to visit the office for financial advice or banking transactions. October 2014 | 17
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Community Trust Bank Honored as “Business of the Year” PIKEVILLE, KY. – Community Trust Bank, Inc. was recently honored by the Southeast Kentucky Chamber of Commerce as the “Business of the Year” for 2014. The award was presented to Jean R. Hale, Chairman, President, and CEO of Community Trust Bancorp, Inc. at the Chamber’s 57th Annual Banquet held in Pikeville, Kentucky. Presenting the award on behalf of the Southeast Kentucky Chamber of Commerce were Jared Arnett, President and CEO of the Southeast Kentucky Chamber of Commerce, and John Blackburn, Chairman of the Southeast Kentucky Chamber of Commerce. Community Trust Bank, Inc., formerly known as Pikeville National Bank and Trust Company, opened in 1903 on Main Street in downtown Pikeville in the same building that is now occupied by its Main Street Branch location. A group of local businessmen chose to begin a tradition of offering safe and October 2014 | 20
sound banking for the community of Pikeville; the Company has been truly blessed since the beginning. The Pikeville National Bank began with $25,000 in capital. Over the years, with strong leadership exhibited throughout the organization from its inception, the bank grew and prospered along with the city of Pikeville and surrounding communities of Pike County. In 1987 Pikeville National Bank & Trust Company began the process of acquiring banks throughout the region and in the state of Kentucky. In 1997 the bank adopted its current name of Community Trust Bank, Inc. The bank continued its acquisition strategy with acquisitions as recently as 2011 that now include the states of Kentucky, West Virginia, and Tennessee. “Our goal each day is to live out our core values of fairness, integrity, and respect as we continue to serve our customers throughout our footprint,” said Jean Hale. “Even though we have expanded
geographically and grown significantly in the last several years, we are still proud to call Pikeville home, as well as the headquarters of Community Trust Bancorp, Inc. We remain extremely loyal to our origins in Eastern Kentucky.” Historically, much of our growth as a company is the result of the region’s strong economy, driven by the coal industry. As our region accepts the current challenges of the coal industry, we will stand by our communities to be a partner in transforming our region to one with a diversified economy. Although coal will continue to make a contribution, we have tremendous growth potential in other business and industry. Community Trust Bank will be there to lead the way. We offer a broad range of both retail and business banking products and services related to loans and deposits, as well as cash management, wealth management and trust services, and investment services. Community Trust Bancorp, Inc.
supports a wide variety of community organizations such as United Way, American Cancer Society’s Relay for Life, Habitat for Humanity, Kentucky Blood Center, Diabetes Coalition, March of Dimes, Boy and Girl Scouts of America, The Salvation Army, Little League sports programs, volunteer sports programs, home realtor and builder organizations, and independent and state supported colleges and universities. We not only support these organizations monetarily, but our employees volunteer thousands of hours each year to these and other excellent community organizations including the Southeast Kentucky Chamber of Commerce and SOAR (Shaping Our Appalachian Region). We remain dedicated to building prosperous caring communities.
“We are proud to say Pike County is our home, the headquarters for Community Trust Bancorp, Inc.” concluded Ms. Hale. “For 111 years we can proudly say that we have had the privilege of knowing our customers in Pike County, and by knowing them, we can better serve them. By serving them, we are helping them reach their financial goals. We look at our customers as family, and they in turn see us as their family and as their trusted financial advisor.” The Southeast Kentucky Chamber of Commerce serves the businesses of Floyd, Johnson, Knott, Lawrence, Letcher, Magoffin, Martin, and Pike
in southern West Virginia, four banking locations in Tennessee, four trust offices across Kentucky, and one trust office in Tennessee. It is the largest bank holding company domiciled in the Commonwealth of Kentucky. Community Trust continues to provide strong returns to its investors; it has increased the cash dividend to shareholders for 34 consecutive years. The stock is traded on the NASDAQ Global Select Market (a founding stock selection) under the symbol “CTBI” and is also one of 50 founding stocks of the NASDAQ’s Dividend Achievers Index.
We are certified lenders for the Small Business Administration (SBA), USDA, as well as being a certified FHLMC secondary market lender for residential mortgages. With other certifications, we have the ability to offer products and services from our strong Trust and Investment Subsidiary. Community Trust Bank was honored by the SBA’s midAtlantic Region as the SBA Community Lender of the year in the state of West Virginia for 2013. “Lenders are a huge part of the SBA partner community, and Community Trust Bank is a big ally for us and business in West Virginia,” said SBA Mid-Atlantic Regional Administrator Natalie Olson-Urtecho. “On April 1, 2014, Forbes Magazine recognized Community Trust Bancorp, Inc. as one of American’s 50 Most Trustworthy Financial Companies. Community Trust Bancorp was also recognized as being first in the nation in the ‘small cap’ category ($250 million to $1Billion). In December 2013, Phillip Danhauer, SBA Finance Chief for Kentucky, presented Community Trust Bank with the “Gold Lender Award” for being Kentucky’s top SBA 7a community bank lender for 2013, an award the bank has now won for the fifth consecutive year. In the last six years Community Trust Bank has funded over 500 SBA loans to its small business partners for over $80 million in funding. 27 different lenders in our Kentucky footprint contributed loans this past year, making this success a cooperative team effort.
Counties. Their mission is, “To establish a support network for businesses in Southeast Kentucky committed to improving the local economy, regional unity, political advocacy, and economic development; ultimately, improving the quality of life for citizens of the entire region.” Their vision is, “A region that ignores county lines in the name of economic growth and improving the quality of life for our citizens.” Their values are unity, integrity, leadership, and service. Community Trust Bancorp, Inc., with assets of $3.7 billion, is headquartered in Pikeville, Kentucky and has 71 banking locations across eastern, northeastern, central, and south central Kentucky, six banking locations
Photo Above Community Trust Bank, Inc. was recently honored by the Southeast Kentucky Chamber of Commerce as the “Business of the Year” for 2014 at the Chamber’s 57th Annual Banquet held in Pikeville, Kentucky. Accepting the award on behalf of Community Trust was Jean R. Hale, Chairman, President and CEO of Community Trust Bancorp, Inc. From left are Jared Arnett, President and CEO of the Southeast Kentucky Chamber of Commerce, Jean R. Hale, and John Blackburn, Chairman of the Southeast Kentucky Chamber of Commerce.
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ON THE MOVE Traditional Bank is excited to welcome Shawn Woolum as a branch manager and loan officer for its Lexington market. Woolum will oversee lending and deposit operations at the new Zandale Banking Center set to open this fall. Woolum is a Bell County, Kentucky native with 12 years of banking experience.
Jerry Pelphrey has been named Community President for First Southern National Bank in Somerset / Pulaski County. Pelphrey, who returned to the First Southern team last fall, has more than a dozen years’ experience in the banking industry, including two years he served with the bank previously as a lender in Garrard County.
Citizens Union Bank welcomes Linda Nolan. Linda will serve as the Vice President/Business & Commercial Banking
Katy Neyhouse was recently promoted to Assistant Vice President, Trust Administrator at WealthSouth, Trust and Investment area of Farmers National Bank. Neyhouse joined Farmers National Bank in 2005. She is a graduate of Campbellsville University and Cannon Trust School. Neyhouse holds the Certified Trust and Financial Advisor designation.
Central Bank Chairman, President and CEO, Luther Deaton, Jr., has announced the promotion of Kevin Lippert to vice president, technology services. Mr. Lippert has been with Central Bank since 2000, when he began his career as a teller. He spent two years working in the retail area of the bank before joining the technology services department in May of 2002.
First Security Bank is pleased to announce Laura Mathis recently joined the bank as the Director of Marketing. An Owensboro resident, Laura has over 25 years of experience in marketing, design, advertising, and publishing, as well as being the sole proprietor of a successful graphic design business.
Central Bank Chairman, President and CEO, Luther Deaton, Jr., has announced that Vina Risner has joined Central Bank as assistant vice president, mortgage loan originator. Vina earned her undergraduate degree in general and cooperative education. Mrs. Risner has been in the mortgage lending field since 1987. She and her husband, Bruce, have one daughter named Mendy and two grandsons, Jonathan and Max.
At the September 16, 2014, Board of Directors’ meeting of the Farmers Bank & Capital Trust Co., T. Alexander Fitzgerald was promoted to Trust Officer. Mr. Fitzgerald graduated from the University of Kentucky with a B.S. degree in Economics as well as Appalachian School of Law in Grundy, VA. A native of Elizabethtown, Alex joined the Farmers Bank Trust Department in November of 2013.
Citizens Union Bank of Shelbyville Loan Assistant, Crissy Sullivan received the AIB Bank Operations and AIB General Banking Diploma. Claudio Monzon, Senior Vice President Retail Lending at CUB presented Crissy with the diplomas. Crissy also transferred many AIB credits and is just a few courses away from earning her Bachelor’s Degree in Accounting. Congratulations Crissy!
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ON THE MOVE First Security, Inc. (The holding company for First Security Bank, Inc.) announced that Amy Jackson has been named as President of the Owensboro Region for First Security Bank. Ms. Jackson comes to the bank from the Greater Owensboro Chamber of Commerce where she served as President & CEO for the past two years.
John Edge, current President of the Owensboro Region of First Security, Inc. recently announced his retirement with First Security after 17 years with the company. Edge is one of the founding key executives that started First Security Bank in 1997. Edge will continue with the bank in a consultative capacity directing his efforts in Business Development and Customer Relations.
Bank of Kentucky Rewards Community Business The Bank of Kentucky is proud to recognize Jude’s Custom Exhaust in Independence, Kentucky, as this month’s “Hometown Business of the Month”. This award is presented to a local business selected by a team of Bank of Kentucky employees who review nominations throughout the month. Similar to how The Bank of Kentucky charted its course over the past 24 years as a local business ingrained in the fabric of Northern Kentucky, businesses that are celebrated each month exemplify what it means to be a valued “hometown” business. Jude’s Custom Exhaust is based on the belief that their customers' needs are of the utmost importance. Their entire team is committed to meeting those needs. As a result, a high percentage of their business is from repeat customers and referrals.
For more information about The Bank of Kentucky’s Hometown Business of the Month, contact Katie Enzweiler, Marketing Specialist at 859-372-2333 or knenzweiler@bankofky.com or Mark Exterkamp, Executive Vice President, Retail at 859-372-2202 or mexterkamp@ bankofk.com. About The Bank of Kentucky: The Bank of Kentucky offers banking and related financial services to both individuals and business customers. The Bank operates 32 branch locations and over 50 ATMs located throughout the region in Boone, Kenton, Campbell, Grant, Gallatin, Pendleton, and Hamilton County. Learn more at www.bankofky.com
Learn more at http://www.judesautoshop.com/About-Us.html.com.
Town & Country Bank & Trust Raises Money for ALS Research Bardstown, KY-- Town & Country Bank and Trust Co. employees raised over $200 for ALS research on Friday, September 12th. Employees were encouraged to wear green to support ALS fundraising and to help raise awareness. The picture shows a snapshot of just a few of the Main Office staff that dressed in green. Later that day Raffo Wimsett, Interim President and CEO, and Will McGinnis, Chief Financial Officer, participated in the Bardstown Mainstreet ALS Ice Bucket challenge on the plaza of the Visitor’s Center with other Mainstreet merchants.
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