August 18, 2020

At times in our country, true independence has arisen from points of crisis — critical moments in time that require us to listen and reflect. Just think about the foundation of our nation so many years ago. A crescendo of events drove actions that ultimately led to the birth of a new nation.

Credit Practices Rule. Q: Regulation AA was rescinded some time ago, but is a Notice to Cosigner still required when we are doing a loan that has a cosigner?
A: Since the repeal of FRB Regulation AA (and similar rules by the Office of Thrift Supervision and National Credit Union Administration), there has not been an explicit requirement for banks, thrifts, and credit unions to give cosigners the Notice to Cosigner. Lenders under the enforcement authority of the Federal Trade Commission are subject to the FTC’s Credit Practices Rule, which requires such a notice (among other provisions).

I am honored to be a featured associate member of the Montana Independent Bankers Association. As I have interacted with my clients in the Montana banking community, I was able to glean some insight into what might be of interest to you in an article. Health benefits are one of the most expensive line items for our Montana Community Banks. The industry changes rapidly and is affected by many factors, including the healthcare system, carrier decisions, new marketplace programs, legislation and many others. In this article, I will discuss national benchmarks, address how COVID-19 could affect health benefits in the future, and review several cost management strategies available to employers.

Phew — what a year these last few months have been.
Just three months ago, many of us were on flights returning from the ICBA convention held in Orlando, Florida.