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October 26, 2022

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Review Your Bank's Cyber Reporting Policies

As Cybersecurity Awareness Month wraps up, take a moment to review your bank's cyber incident reporting policies and cyber liability insurance. 


As of May 22, 2022, banks are required to notify their primary Federal regulator of any “computer-security incident” within 36 hours of the incident. Details on the requirements are available here


Additionally, management should contact their cybersecurity insurance carrier and/or agent to check for their reporting requirements and update their reporting policy to include anything additional the company may require.


As your bank prepares to renew cyber liability insurance, please be aware of the minimum requirements to secure renewal terms:

  • Multi-factor authentication for cloud-based services and all remote access to your network
  • Virtual private network for remote access into your network
  • Cyber security training is provided at least annually to all individuals with access to your network or confidential/personal data
  • Critical patches and updates implemented within 2 months
  • Incoming emails scanned for malicious attachments or links
  • All network devices are protected with anti-virus, anti-malware or endpoint protection software
  • Critical data is backed up regularly


For a comprehensive review of your bank’s insurance coverage, contact Mitch Florea at NBISCO at 402-904-7014 or [email protected].

Legislative, Policy & Regulatory Updates

Appellate Court Finds CFPB Funding Structure Unconstitutional

A three-judge panel of the Fifth Circuit Court of Appeals ruled that the Consumer Financial Protection Bureau's (CFPB) funding structure violates the separation of powers clause of the Constitution. The CFPB receives funding from the Federal Reserve System, instead of through the annual appropriations process. The court also vacated the CFPB's 2017 small-dollar lending rule.

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FDIC Survey: Number of Unbanked Consumers Declines

According to the 2021 National Survey of Unbanked and Underbanked Households, only 3% of Nebraskan households are unbanked, a 3.6% decrease from 2019. Nationally, 4.5% of households do not have a bank account, the lowest figure since the survey began in 2009. Nearly 22% of unbanked survey respondents said not having enough money to meet minimum balance requirements was the main reason they did not have an account at a depository institution. "Don't trust banks" was cited by 13%.

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CFPB Issues Guidance on Deposit Account ‘Junk Fees’

The CFPB today released information on junk fee practices. Junk fees are defined as fees charged to consumers that are not reasonably related to the costs incurred by the financial institution. A circular on unanticipated overdraft fee assessment practices and a compliance bulletin on depositor fees clarify when a bank’s policies could violate the Consumer Financial Protection Act. 

Read the Overdraft Fees Circular

Read the Depositor Fees Bulletin 


Fannie Mae, Freddie Mac to Require New Credit Score Models

After a multiyear transition period, lenders will be required to submit both the FICO 10T and VantageScore 4.0 credit scores for loans sold to Fannie Mae and Freddie Mac. In addition, three credit reports will be required. 

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Upcoming Events

To see the complete event schedule, visit the NBA Event Calendar.

Graduate Schools of Banking Opportunities 

The Graduate School of Banking-Wisconsin (GSB-Wisconsin) and the NBA are sponsoring multiple schools in 2023, including a Bank Technology Management School and a Digital Banking School. View next year’s full schedule here.

The NBA and GSB-Wisconsin are also co-sponsoring online seminars during the rest of 2022. For more information, view the schedules by date: October | November/December.

Enrollment is open for the Graduate School of Banking at Colorado’s next session, held July 16-28, 2023, in Boulder, CO. Learn more and apply here

Banks & Bankers

Oct. 19 - 25


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Farm Program Enrollment Open

Agricultural producers can make 2023 crop year elections for the Agriculture Risk Coverage and Price Loss programs through March 15, 2023. 

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Bankers Needed to Connect with Scholarship Applicants

One of the requirements for the NBA Foundation scholarship is a letter from a banker. We’re looking for bankers to meet (virtually or in person) with scholarship applicants who do not have an existing relationship with a banker. Sign up here if you want to help.

It’s an opportunity for students interested in banking to connect with a banker and learn more about the industry. It’s also an opportunity for bankers to meet with future bankers and share why banking is a great career.

Applicants are interested in a wide variety of roles in banking. We will work to connect you with a student who shares your areas of interest. 

If you do know a college student at a state or private university in Nebraska who would make a great banker, be sure to share this scholarship opportunity. The application and the complete list of requirements are available here

For more information, contact Kara Heideman at the NBA at [email protected] or 402-474-1555.

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