Oklahoma Bankers Association We make bankers better!
In This Issue…
- From Adrian’s desk …
- SBA orders banks to report on ‘debanking’ actions
- Disparate impact removed from FDIC exam manual
- OCC lowers semiannual assessment rates
- OBA Emerging Leaders Academy taking applications
- OBA TikTok Time …
- OBA education corner …
From Adrian’s desk …
By Adrian Beverage
OBA President & CEO
Just some random tidbits that might be of interest to our bankers this week!
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I was down in Texas this long Labor Day weekend, watching some youth baseball! Couldn’t have picked better weather for it, that’s for sure! How did you spend your Labor Day weekend?
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Our first board meeting of the 2025-26 year went off without a hitch last week! I particularly enjoyed a chance to meet the new faces on the board during our annual dinner the night before!
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We’re less than two weeks out from our Annual Washington Visit, which just blows my mind as it seems its sneaked up on us so quickly!
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My Cornhuskers started the season with a nice “W” this weekend, although I can say I was sweating it a bit there at the end! With Cincinnati in our rear-view mirror, we have a couple cupcake games to feast on before the maize and blue of Michigan visit Lincoln … just a couple weeks after they are in Norman!
SBA orders banks to report on ‘debanking’ actions
On Aug. 7, the Small Business Administration sent a letter to over 5,000 lenders in response to President Trump’s executive order “Guaranteeing Fair Banking For All Americans.”
The letter outlined the executive order and ordered banks to follow the new order.
Pursuant to the Fair Banking Executive Order, banks are required to take the following action:
- By Dec. 5, your institution must identify any past or current formal or informal policies or practices that require, encourage, or otherwise influence your institution to engage in politicized or unlawful debanking as specified by the Fair Banking Executive Order.
- By Dec. 5, your institution must make reasonable efforts to identify and reinstate any previous clients of your institution or any subsidiaries denied service through a politicized or unlawful debanking action in violation of a statutory or regulatory requirement under section 7(a) of the Small Business Act (15 U.S.C. 636) or any requirement in a Standard Operating Procedures Manual or Policy Notice, and send notice of the reinstatement to the injured party;
- By Dec. 5, your institution must identify all potential clients denied access to financial services provided by your institution or any subsidiaries through a politicized or unlawful debanking action in violation of a statutory or regulatory requirement under section 7(a) of the Small Business Act or any requirement in a Standard Operating Procedures Manual or Policy Notice, and provide notice to each otherwise qualified client advising of the denied access and the renewed option to engage in such services previously denied; and
- By Dec. 5, your institution must identify all potential clients denied access to payment processing services provided by your institution or any subsidiaries through a politicized or unlawful debanking action in violation of a statutory or regulatory requirement under section 7(a) of the Small Business Act or any requirement in a Standard Operating Procedures Manual or Policy Notice, and provide notice to each victim advising of the denied access and the renewed option to engage in such services previously denied.
The OBA is working with members of our delegation as well as the ABA to gather as much information as possible. There are still numerous questions that haven’t been answered by the SBA, and we need additional information so you will know exactly what is and isn’t required from you. We’ll keep all our bankers informed as we gathered and decipher new information.
Disparate impact removed from FDIC exam manual
The FDIC announced late last week it had removed all references to disparate impact from its Consumer Compliance Examination Manual.
Instead, the agency said it will evaluate potential discrimination under the Equal Credit Opportunity Act and Fair Housing Act “only through evidence of disparate treatment.”
President Trump issued an executive order in April to eliminate enforcement of disparate-impact liability, which since the early 1970s has allowed courts to halt policies and practices that, while facially neutral, seem to exclude people based on characteristics such as race, gender and disability. The administration alleged that such liability “handcuffed” employers by requiring them to consider race and “racial balancing” to avoid legal liability.
The removal comes after the OCC did the same with its documentation in July.
OCC lowers semiannual assessment rates
The Office of the Comptroller of the Currency announced last week a decrease in assessment rates for the Sept. 30 semiannual assessment.
The OCC reduced the rates in the general assessment fee schedule by 30% for assets up to $40 billion and 22% for assets above $40 billion, and reduced the rates in the independent trust and independent credit card assessment fee schedules by 22%, according to the agency. The OCC is also decreasing the hourly fee for special examinations and investigations to $137 from $176.
This is the fifth decrease in assessments since 2017 and will apply to all OCC-regulated institutions, the agency said.
OBA Emerging Leaders Academy taking applications
Take note the OBA 2025-26 Emerging Leaders Academy is currently accepting applications. We’re looking for the best and brightest bankers who seek to sharpen their leadership skills.
There are six sessions to the Academy: Nov. 13, Dec. 11, Jan. 23, Feb. 25, March 27, April 24. Each session delivers takeaways that can be implemented immediately. Graduation will take place in May 2026 at the OBA Annual Convention.
Academy applicants should be able to demonstrate an increasing level of responsibility, potential for continuing to play a leadership role in Oklahoma banking and a desire to further their careers and grow professionally. A panel of bankers will review the applicants and choose those accepted into the Academy (maximum 30 bankers).
Click here to apply! The application deadline is Sept. 26. For more information, please contact Megan McGuire at megan@oba.com or (405) 424-5252.
OBA TikTok Time …
Welcome to the continuation of our semi-regular feature in the OBA Update: OBA TikTok Time!
The OBA created a TikTok account to feature fun, entertaining little video segments that feature our bankers and those who work with them. No, a TikTok account is not required to view these short videos as you can navigate directly there just by using the link we provide here in the OBA Update. For those concerned about security via TikTok, you can also easily view the videos through our Instagram account. We’ll feature our most recent TikToks in the TikTok Time … corner of various upcoming OBA Updates.
For this edition, we visited with random members of our OBA board to ask them about the absolute most important news of the millennium: Where were they when they found out Taylor Swift and Travis Kelce were engaged?
OBA education corner …
Labor Day is the unofficial end of summer, and we like to mark it by listening to one of the greatest – the greatest? – end-of-summer songs every put onto sheet music: The Boys of Summer, by Don Henley. So, while realizing nobody is on the road and nobody is on the beach and you’re sitting back with those Wayfarers on, we hope you also have time to check out what’s happening on the continuing education front, including the following:
- Fall Human Resources Seminar, Sept. 9, Oklahoma City — We will explore some of the changes in 2025 which have added a lot of confusion to HR. Understanding and getting thru this maze will help us get through more changes.
- Loan Documentation 101: 2-Part Series (can do either or both), Sept. 11-12, webinar — Learn about basic secured loan documentation, lien perfection and business collateral in this two-part series.
- Cyber Security 101, Sept. 18, webinar — Attend this session to understand the principles of cybersecurity, review the common security threats which concern your institution and review practical security controls which can safeguard your financial institution.
- Credit Analysis Basics, Sept. 18-Tulsa; Sept. 19-Oklahoma City — Attend this proactive seminar and learn how banks make lending decisions based on the five C’s of credit: capacity,
capital, collateral, conditions and character! - W-9s, W-8BENs, and Interest Reporting: IRS Mismatches and Errors, Sept. 23, webinar — During this program, we will do a line-by-line review of the forms and the subsequent tax reporting to the IRS.
- Community Bank Cryptocurrency Primer Workshop, Sept.23, webinar — It is essential for community banks, no matter the size, to understand the crypto economy, the illicit typologies, and have open-source tools in hand to investigate when needed.
- Real Estate Lending Compliance, Oct. 1-2, Oklahoma City — This program provides an overview of the real estate lending requirements from 10 regulations, along with comprehensive coverage of selected topics, policy suggestions, employee training tips, audit techniques and steps to eliminate past problems.