Bequeaith Banking Solutions Company History

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Bequeaith Banking Solutions Company History Our company was established in July of 2005 and provides regulatory compliance testing, training and problem solving to P nancial institutions and trade associations seeking the best solution in their market. We are headquartered in the Kansas City and serve select clients in other metropolitan markets as well. Our goal is to simply be the provider of choice in the markets we serve and a reliable advisor to long-term clients.

Our Principal is David Bequeaith, CertiP ed Community Bank Compliance OfP cer (CCBCO) and CertiP ed Regulatory Compliance Manager (CRCM). He can be reached at David@bqbanking.com. Jackie Keglovits is our OfP ce Manager and a contact for you when others are not readily accessible while in the P eld.

She can be reached at Jackie@bqbanking.com or 913-663-1170. Lindsay LaNore serves our Twin Cities area clients while supporting our national compliance help line and editing professional training materials. She has served in a compliance consulting role at a large accounting P rm and most recently coordinated compliance testing efforts at a larger community bank.

She can be reached at Lindsay@bqbanking.com or (651) 636-3699. Our collective experience (regulator, banker and consulting) and history of success allows us to also serve ... more. less.

in a support role to national trade associations such as the Independent Community Bankers of America (ICBA) and the Bank Administration Institute (BAI). See our speaking and training calendar for more information. Financial institutions realize that compliance can be differentiator. Those banks capable of managing the risks and yet adapting to new opportunities will be the survivors. We want our clients to be the survivors and will use our testing, training and problem solving skills to help make this happen. News from Bequeaith Banking SolutionsVolume 1 Number 1 News from Bequeaith Banking SolutionsVolume 1 Number 1 www.bqbanking.com Learning Resources ICBA Compliance Institute: Fundamental compliance training for inexperienced and veteran bankers. Over 1,000 bankers have attended this program to establish their understanding of compliance management and regulations. Most have survived. Kansas City in June and St. Louis in October. See www.icba.org or e-mail david@bqbanking.com for more detail. ICBA Advanced Compliance Seminar: Half week roundtable seminar for advanced compliance professionals who want to increase their knowledge of current best practices and hot topic regulations through facilitated discussion with high-level peers. Scottsdale in March (I P nally have some say on location!) See www.icba.org or e-mail david@bqbanking.com for more information. ICBA Bank Secrecy Act Professional Certi0 cation: New for 2007, this certiP cation program will deliver a rigorous BSA, AML, CIP and OFAC training curriculum to P nancial industry managers and auditors and is followed by a two part test to achieve national certiP cation. Scottsdale in March (see previous location comment) and www.icba.org for more detail. BSA/AML 3-Part Video Series: Focused training delivered via DVD and directed at Frontline Employees, Directors and Executive Management, BSA/AML OfP cers. Each video segment is tailored to the three targeted audiences and succinctly provides topical annual training needs in a 30 to 45 minute time frame. See www.icba. org or e-mail david@bqbanking.com for more detail BAI Annual Loan Review Best Practices Survey: Comprehensive survey of loan review practices across the banking industry. Delivered annually at the BAI Loan Review Annual Conference. See www.bai.org or contact David Bequeaith at david@bqbanking.com for the current survey. Custom Training: Regulatory compliance training customized for the needs of your bank. Call or e-mail for more information. \x4\x2 \x2 \x3 \x7\x9\x4\x8\x3 \x2 Not to be outdone by our regulatory friends, we have our own TLA (Three Letter Acronym) that we follow. It 9s simply: Accurate, Relevant and Timely, or ART. Accurate Many assumptions and errors are made by bankers and third parties that are caused by an unsupported and inaccurate understanding of the regulatory requirements. We research each situation to determine what is required by the regulation and present a cbest practice d solution for your setting. Relevant A myriad of regulations impact banks in differing degrees. Some lead to penalties or have reputation risks while other errors prevent banks from pursuing new opportunities. All must be evaluated for the speciP c impact, exposure, and control needs within each bank 9s unique environment. We prioritize our observations and recommendations in light of their respective risks. Timely Business and process owners want valuable information that is accurate, relevant and in their possession in time to help. We provide immediate, on-site feedback to all levels of staff, present formal outlines at exit and deliver an electronic report expeditiously. www.bqbanking.com 5350 College Boulevard Overland Park, KS 66211 913.663.1170 The proliferation of fraudulent cashier 9s checks has created a need to protect the Bank from loss through application of the hold practices outlined in Regulation CC. Admittedly, we already struggle with hold applications due to the arcane rules within the regulation but a renewed effort will protect the Bank and avoid regulatory scrutiny during your next examination. Can Do with Cashier 9s Checks 3 Place Exception Holds such as: " Large Deposit (In excess of the P rst $5,000) " Repeat Overdraft " Redeposited Checks " New Account Holds (In excess of the P rst $5,000) Can 9t Do with Cashier 9s Checks: " Place Reasonable Cause to Doubt Collectibility " Exception Holds arbitrarily on Cashier 9s Checks without some knowledge of fraud, etc. " Check your fraud alerts (summarize for tellers) " Call the paying bank " Develop a grid on accepting checks based on tenure of account, average balance, etc. " Place Case by Case holds on Cashier 9s Checks " Create your plan of action for these checks and conduct training with the frontline personnel who place holds Oldie but a Goodie 3 Funds Availability and Holds on Cashier 9s Checks Bankin 9 Bits " Visit our new website at www.bqbanking.com " Bequeaith Banking Solutions, LLC will be repeating its BSA/AML audio training series beginning this January. This three-part series can meet your annual training requirements for the Bank Secrecy Act and is targeted at three speciP c audiences, including Frontline Personnel, Directors & Management and BSA/AML OfP cers. Contact us for more information or visit www.icba.org. " The Interagency Guidelines on Commercial Real Estate lending practices were recently released and represent potentially signiP cant work on your part depending upon your level of real estate lending. Make sure you review them carefully and can articulate your institution 9s position and monitoring efforts. Contact us if you would like input on this effort. " Need more in-depth BSA/AML training and guidance? Enroll in the ICBA 9s Bank Secrecy Act Institute in Scottsdale this March where you can earn a formal certiP cation in this P eld through completion of a rigorous three day training program. www.bqbanking.com News from Bequeaith Banking SolutionsVolume 1 Number 1 www.bqbanking.com BQ Reflections Most Direct Boss Bernie, the Urbandale, IA FDIC Field OfP ce Supervisor. Ex-Marine Sergeant who chain- smoked P lterless Camels in the close conP nes of our ofP ce and whose colorful and direct language would not likely pass muster today. You knew where you stood at all times with Bernie. Best Learning Experience The Southgate Bank, Prairie Village, KS. As a three-year examiner, I thought I knew everything about banking and serving as Internal Auditor, Compliance OfP cer and Loan Review OfP cer. After one week I realized that I knew relatively little about banking and that applying regulations in real time would be a challenge. Most Rigourous A stint for Sheshunoff at the Inn at Spanish Bay on the Monterrey peninsula. This week long assignment called for staying at the luxurious $600+ per night Inn, facilitating a 2-hour CEO session at 11:00 AM before teeing it up along the PaciP c for a twilight 18 holes every afternoon. DeP nitely consulting at its most rigourous! Most Insightful Serving as the lead consultant at Riggs Bank N.A. for six stressful months in 2004. The game got more serious two weeks into the engagement when the Bank was P ned $25 million for Anti-Money Laundering program weaknesses but thankfully our team of Sheshunoff compliance professionals dug in and helped the Riggs staff make it through the next examination. Best Employer Generated Opportunity FDIC hands down. The extravagant 1987 regional conference at the Tan-Tar-A resort in Lake of the Ozarks introduced me to Amber Arnett, now Amber Arnett-Bequeaith, wife of 14 years and mother to our four Bequeaith children. Thank you Bill Seidman and Charlie Thacker! Instructors Corner with David Bequeaith, Principal Consultant Bequeaith Banking Solutions, LLC Blazing a Trail to Your Bank I always begin the Sunday evening session of the week long endurance test known as the ICBA Compliance Institute with my graphical representation of where community banks are on a chart of regulatory enforcement levels. This year we may have to order a heightened Q ip chart because our exposure is simply off of the charts. Public P nes and enforcement actions are routine while the informal actions and expectations that are not public have increased as well. But it goes beyond, cStaying out of trouble. d Community banks are in P ght for survival. FDIC statistics show that the number of bank and thrift charters nationally has declined from 9,904 to 8,854 in the past P ve years, a reduction of nearly 11%. Furthermore, the number of commercial banking charters with total assets less than $1 billion has declined from 7,918 to 7,075 in the same time period. I was attending a meeting of more than 20 nationally known instructors this spring and our consensus was that charter numbers would dip possibly as low as 6,500 in the next P ve years before stabilizing. As an industry service provider, those are frightening numbers. Banking charters continue to consolidate to meet shareholder needs. A part of that need includes meeting difP cult regulatory requirements with compliance, internal audit and training efforts spread too thin across an organization. Nonetheless, all P nancial institutions face demands to provide an adequate return to shareholders by continuing to: " Reduce costs through more efP cient operations. " Treat customers in a fashion that will ensure retention of the right customers. " Develop new products and services to meet existing customer needs and attract new customers. Standing P rmly in the path of the three agendas above is the increasing level and enforcement of regulatory compliance. In short, the compliance function has become a key player in your long term success. In the past P ve years, the community bank industry has seen the role of the compliance ofP cer evolve from a transactional reviewer to a risk management executive. Community banks that have made that transition are ahead of the curve, those that have not face a tougher challenge to comply. In short, regulatory risks for the community bank are a signiP cant and growing barrier to growth and proP tability. New roles that your compliance function needs to fulP ll include moving from barrier to enabler. In short; " Support product and service development by maintaining your compliance knowledge at a high level and interacting with peers. " Don 9t assume the cNo! d position automatically. Look at the product/ service need, evaluate the risk/reward trade-off and establish minimum controls to ensure regulatory compliance. " Educate the base with Bank procedures and cultural expectations. It won 9t be easy but we believe the institutions that are survivors P ve and ten years from now will be supported by high-performance risk management functions. We aim to help those so inclined to meet that goal. The onslaught of new, revised or newly interpreted regulations in the past three years has been relentless. Here are some recommendations for several hot topics that you are reading and hearing about: BSA Interagency Examination Manual Update: Not a great deal here for the average bank since they have just reorganized the manual and incorporated previously published material. There are a few follow ups or points of interest to direct to your BSA/AML OfP cer: 1. You are more responsible for your own documented risk assessment. 2. Auditors should take advantage of the new format. 3. If an outside party performs your BSA Independent Test. You are more responsible for your own documented risk assessment. Ask us if you need help. Auditors should take advantage of the new format and clariP ed testing procedures to do the independent test properly. If an outside party performs you BSA Independent Test, look carefully at the interagency standards and ensure that your testing party is measuring up. FCRA Red Flag Guidelines: This regulation (V) is slowly but surely rolling out implementation for the long- ago FACTA mandated updates. The regulations are still only in the proposal/ commentary phase but your operations and credit personnel should become aware of the following by year end. A cRed Flag d for this regulation is deP ned as a cpattern, practice, or speciP c activity that indicates the possible risk of identity theft. d The proposed and P nal version will require another formal program, risk assessment and procedures. This format is becoming familiar. All of the proposal language places much accountability on the BOD for approval, implementation and monitoring annually. Background Checks: There is much current discussion about background checks and pre-employment screening. This stems from the two-pronged regulatory focus on information safekeeping and identity theft. You can P nd insightful guidance in the FFIEC Information Technology Handbook and even more focused guidance in the FDIC FIL 46-2005 (June 1, 2005). Each bank will want to establish a formal program that is based on an evaluation of the access and sensitivity of each position. This program may include the following: " Verify identiP cation information, past employment and personal references search federal and local public databases for criminal acts. " Requesting access to the applicants 9 consumer credit report. If you choose to access job applicant 9s credit reports, please understand the requirements in the Fair Credit Reporting Act. " Requires written consent from the applicant. " If you make adverse action based on credit report content. " Must make report available to the employee/applicant before communicating same. Also provide summary of rights under FCRA (std FTC language found on site) A Beginning August 16, 1986; a watershed day for the banking industry. OK, maybe it wasn 9t that dramatic but it was the P rst day of employment for a very green Assistant Bank Examiner, David Bequeaith, GG-5. My P rst day of professional employment was at the FDIC Regional OfP ces in Kansas City, MO and I had a lot to learn beyond the experiences of my low balance passbook account at the local savings and loan in receivership. After the obligatory P ngerprinting, ID picture and video training on how to sneak up on a community bank for a surprise examination, I was on my way. Despite our training, I found that we remained conspicuous in our new suits (courtesy of the FDIC $1,500 clothing advance) and banking nerd bags and caught many a glare at the local coffee shop over lunch. The early years were safety and soundness focused as the banks not closed in the Midwest were still struggling with severe credit problems and each examination was a test of capital and survival. Those were tense times and a good way to learn credit risk in the trenches. After accidentally shredding the P eld ofP ces 9 permanent P les for Compliance examinations, the Field OfP ce Supervisor cynically made me the compliance trainee. This experience served me well as we reintroduced the compliance examination in the late eighties. It also helped me move over to the fun side of banking as Compliance OfP cer, Loan Review OfP cer and Auditor at a Kansas City area community bank. Twenty years later, that initial training and insight for the regulatory process still comes in handy.

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