SDBA eNews winter

February 12, 2026

News

ABA Banking Journal: ABA urges OCC to provide stronger safeguards, clearer rules for charter applicants
ABA Banking Journal Democrats urge courts to stop efforts to ‘dismantle’ CFPB
ABA Banking Journal: FHFA finalizes repeal of fair lending rule
CISA News: The Iceberg Effect

SDBA Updates

Order your 2026 Scenes of South Dakota Calendars

SDBA Events

2026 SDBA "This is How We Roll
2026 SDBA IRA Spring Update
2026 Understanding Bank Performance
2026 GSBC Annual School Session

Online Education

Additional Educational Opportunities

ABA Banking Journal: ABA urges OCC to provide stronger safeguards, clearer rules for charter applicants

February 11, 2026

As the Office of the Comptroller of the Currency considers revising its chartering rules, the agency should seek to uphold strong safety and soundness standards, increase transparency in the chartering process, and move cautiously as new regulatory frameworks develop, the American Bankers Association said today. ABA also called for updated naming rules to ensure charter applicants do not misrepresent the services they intend to offer.

The OCC in January proposed to amend its chartering regulations to clarify that national banks are not limited to performing fiduciary activities. In a letter to the agency, ABA emphasized that the OCC must “ensure that robust, broadly applicable safety and soundness standards are well understood and upheld during this period of rapid innovation” and encouraged the agency to increase transparency throughout the chartering process.

ABA noted that the responsibilities of many recent and likely future charter applicants “are not readily identifiable today because Congress and federal and state regulators have not yet adequately defined regulatory frameworks applicable to entities engaged in stablecoin and other digital asset activities.” The association asserted that the proposed amendment to the chartering regulation is material and merits continued deliberation given its “likely outsized role in the development and implementation of a number of other agencies’ pending rulemakings.”

The letter also highlighted the need for strong safeguards around resolution planning. ABA “strongly encouraged the OCC to ensure that its receivership capacities and related powers and practices are adequate to address any insolvency risks raised by any existing or new OCC charter applicant,” particularly those experimenting with new business lines and unfamiliar operational risks.

As part of its recommendations, ABA stressed the importance of name accuracy for chartered entities to avoid misleading consumers. The association encouraged “OCC to amend its regulations to prohibit any charter applicant – other than a subsidiary of a bank or bank holding company – that limits its activities to either ‘fiduciary activities’ or ‘the operations of a trust company and activities related thereto’ from including the word ‘bank’ in its name.” ABA said that this step would help ensure entities “not have a title that misrepresents the nature of the institution or the services it offers.”

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ABA Banking Journal: Democrats urge courts to stop efforts to ‘dismantle’ CFPB

February 10, 2026

Nearly 200 Democratic and independent members of Congress this week filed an amicus brief urging the courts to halt what they said is the Trump administration’s attempt to dismantle the Consumer Financial Protection Bureau.

CFPB Acting Director Russell Vought has laid off most of the bureau staff, closed bureau offices and declined to request funding for the agency from the Federal Reserve. His actions have been challenged in federal court by the union representing CFPB employees and by Democratic state attorneys general. Separate courts have paused the layoffs and directed the Trump administration to continue funding the agency, although the lawsuits are still ongoing.

In an amicus brief filed ahead of a U.S. Court of Appeals for the D.C. Circuit hearing later this month, the lawmakers argue that the Trump administration’s actions are unconstitutional because only Congress has the authority to create and abolish government agencies.

“Because the power to abolish executive branch agencies belongs to Congress, [administration officials] cannot unilaterally shutter the CFPB nor render it incapable of fulfilling its statutory obligations,” they said. “Allowing them to do so would not only irreparably harm America’s consumers and the national economy but also wreak havoc on our constitutional separation of powers.”

In conjunction with the court filing, the Democratic minority on the Senate Banking Committee released a report alleging that the administration’s efforts to close the CFPB have cost Americans up to $19 billion over the past year.

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ABA Banking Journal: FHFA finalizes repeal of fair lending rule

February 10, 2026

ABA, groups urge FHA to improve loss mitigation options for borrowers The Federal Housing Finance Agency has repealed a 2024 final rule that codified many of its existing practices and programs regarding fair housing and fair lending oversight of Fannie Mae, Freddie Mac and the Federal Home Loan Banks.

Last year, FHFA proposed to repeal the Fair Lending, Fair Housing and Equitable Housing Finance Plans regulation, citing President Trump’s executive order directing federal agencies to repeal “unnecessary” regulations. The agency recently announced in the Federal Register that after taking public comment, it has adopted the repeal, which goes into effect on March 9.

Among other things, the 2024 rule made changes to Fannie’s and Freddie’s Equitable Housing Finance Plans to promote greater accountability; added oversight of unfair or deceptive acts or practices to FHFA’s fair housing and fair lending oversight programs; required additional certification of compliance by all the entities; and established more precise standards related to fair housing, fair lending and equitable housing principles for the entities’ boards. It also created a new requirement for FHLBs to annually report on any actions they voluntarily take to address barriers to sustainable housing opportunities for underserved communities.

In its repeal, FHFA said that while the Equitable Housing Finance Plans outlined in the 2024 rule may offer a broader reach than the existing affordable housing goals and Duty to Serve programs, the latter two “are grounded in statute and subject to rigorous performance evaluation and enforcement mechanisms.”

“As such, these programs are designed to address persistent disparities in access to mortgage credit and housing finance, including those affecting rural, manufactured housing and other underserved markets,” the agency said. “The programmatic structure provides a durable and enforceable framework for advancing access to the housing finance system.”

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CISA News: The Iceberg Effect

January 28, 2026 | Halcyon

Why Ransomware Costs 10× More Than You Think

When organizations budget for ransomware risk, they typically focus on two numbers: the potential ransom payment and the cost of recovery. In 2024, these figures averaged $1 million and $2.5 million respectively, substantial amounts that understandably dominate board discussions and insurance negotiations. But here's the uncomfortable truth: these visible costs represent only the tip of the iceberg. The total financial impact of a ransomware attack typically exceeds these headline figures by five to ten times, with consequences that ripple through organizations for years after systems are restored.

What You See: The Obvious Costs

The visible costs are straightforward to quantify. Ransom payments, when made, now regularly exceed $1 million for mid-size organizations and can reach tens of millions for large enterprises or critical infrastructure targets. Recovery costs, encompassing incident response teams, forensic investigation, system restoration, and overtime for IT staff, average $2.5 million but can balloon significantly higher depending on the attack's scope and the organization's preparedness.

These numbers are real, immediate, and painful. They appear on balance sheets, trigger insurance claims, and dominate post-incident reviews. But they tell only a fraction of the story.

Below the Waterline: The Hidden Costs That Sink Organizations

Business Interruption: The Revenue Hemorrhage

Every hour that critical systems remain offline translates directly to lost revenue. For financial services firms, this means trading platform unavailability, payment processing disruptions, online banking outages, branch system failures, and customer service paralysis. A regional bank generating $2 billion in annual revenue loses approximately $5.5 million per day during downtime. With average recovery times reaching 22 days, business interruption losses alone can exceed $120 million, dwarfing both the ransom and recovery costs combined.

For retailers, manufacturers, or healthcare providers, the calculus is equally devastating. Production lines halt. Supply chains freeze. Patient care gets diverted to other facilities. The longer systems stay down, the more customers, patients, or clients seek alternatives, and many never return.

Regulatory Penalties and Legal Exposure

Ransomware attacks increasingly involve data exfiltration, triggering a cascade of regulatory obligations. HIPAA violations in healthcare can result in penalties reaching millions of dollars. GDPR fines in Europe can total 4% of global annual revenue. State-level breach notification laws add layers of compliance complexity and cost.

Beyond regulatory penalties, class action litigation from affected customers, patients, or partners has become standard following major breaches. Legal fees, settlements, and judgments can accumulate for years after the initial attack. Credit monitoring obligations for affected individuals add millions more in ongoing costs.

The Brand Damage You Can't Repair

Brand strength significantly influences recovery outcomes, but its impact is asymmetric. Organizations with established, beloved brands often weather ransomware incidents with relatively limited customer attrition. Their trust reserves, built over decades, provide cushion during crisis.

But institutions without strong brand loyalty face existential threats. In markets with frictionless switching mechanisms, such as the UK's open banking regulations where customers can transfer accounts with a single click, trust erosion translates immediately to customer departure. When confidence disappears, so do customers, and they rarely return.

This dynamic creates a vicious cycle: organizations with weaker brands suffer disproportionate customer losses, reducing revenue and limiting resources available for future security investments, which increases vulnerability to subsequent attacks.

M&A Valuation Impact

Oliver Newbury, former CISO at Barclays and current Halcyon Chief Strategy Officer, identifies another hidden cost: "For financial services firms that are involved in M&A transactions, where companies are in a process around M&A, like in the private equity space, there can be impact for those companies that are about to be acquired."

A ransomware attack during due diligence can torpedo deals entirely or trigger significant valuation haircuts. Private equity firms and strategic acquirers view recent breaches as indicators of systemic risk, operational immaturity, and potential hidden liabilities. The resulting valuation impact can reach hundreds of millions of dollars, far exceeding any direct attack costs.

Cyber Insurance Premium Shock

Organizations experiencing ransomware attacks routinely face cyber insurance premium increases of 30% to 100% at renewal. For large enterprises paying millions annually in premiums, this represents an ongoing cost burden lasting years. Some organizations become effectively uninsurable in the aftermath of major incidents, forcing them to self-insure against future attacks.

Operational Disruption and Workforce Impact

The human toll of ransomware extends beyond spreadsheets. IT and security teams report widespread psychological strain following attacks, with 41% experiencing increased anxiety, 34% feeling guilty that the attack wasn't stopped, and 31% taking mental health-related absences. Staff turnover accelerates as burned-out employees seek less stressful environments.

Replacing experienced security professionals costs 50% to 200% of annual salary when accounting for recruitment, onboarding, and productivity loss. Organizations hit by ransomware often lose their most talented security staff precisely when they need them most.

Long-Term Operational Changes

Beyond immediate response costs, ransomware attacks force expensive operational changes. Legacy systems require replacement. Security architectures need redesign. Additional tools, staff, and processes become necessary. These long-term investments, while valuable, represent costs directly attributable to the attack, costs that compound year after year.

The Real Equation

When you total the visible and hidden costs, ransom, recovery, business interruption, regulatory penalties, litigation, brand damage, insurance increases, workforce impact, and operational changes—the comprehensive financial impact of a ransomware attack routinely reaches $25 million to $250 million for mid-size to large organizations. The ransom payment becomes a rounding error in this calculation.

Organizations that understand this full cost structure make different decisions about prevention and resilience investments. Spending $1 million annually on specialized ransomware defenses seems not just reasonable but essential when a single prevented attack avoids $100 million in total impact.

The iceberg metaphor isn't just a visual device, it's an accurate representation of ransomware economics. What you see above the waterline is alarming. What's hidden below can sink the entire organization. Smart executives account for both.

Learn more: What Financial Services Organizations Need to Know About Ransomware Resilience

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2026 SDBA "This is How We Roll" -- And it's not business as usual

ROLL 2026 is a whole new experience! We’ve flipped the script to create an event that’s interactive, engaging, and designed to work for you. This year, you won’t just sit back—you’ll jump in.

Meet us at one of four locations across South Dakota to:

See how you fit into the bigger SDBA picture
Connect with bankers from every corner of the state
Uncover meaningful ways to get involved with SDBA
Share ideas and perspectives with peers at all levels

Locations

Rapid City - April 14
Pierre - April 16
Aberdeen - April 21
Sioux Falls - April 22

Bankers of all roles and experience levels will benefit from attending! Better yet—bring a colleague who’s new to SDBA or someone who hasn’t attended before. You’ll both be entered to win a fun door prize, and it’s a great way to introduce others to the value of SDBA while building connections together.

✔️ FREE to attend
✔️ Open to ALL bank employees
✔️ Registration required to ensure accurate meal counts

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2026 SDBA IRA Spring Update

March 11, 2026 | Sioux Falls

The IRA Update builds on your knowledge of IRA basics to address some of the more complex IRA issues your financial organization may handle. This course includes how the transitions rules work, RMDs and death distributions. We will also discuss amending documents. This is a specialty session; some previous IRA knowledge is assumed. The instructor uses real-world exercises to help participants apply information to job-related situations.

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2026 Understanding Bank Performance

April 2, 3, 9, 10, 16, 17, 23, 24 | 10am-12pm CST | Virtual

Participants will learn how to assess and analyze a bank’s financial performance by working with data from real institutions. Using financial statements from one sample financial institution along with statements from their own banks, participants will become familiar with the ins and outs of balance sheets and income statements and learn how to apply key performance metrics to the data presented in these documents.

Having learned how to interpret and analyze a bank’s financial statements, participants will gain deeper insight into the factors affecting bank performance. Later sessions in this course will address ways in which performance may be hindered or improved by funding strategies and risk management. Ultimately, participants will be able to review a bank’s financial statements to identify strengths and weaknesses and be able to recommend changes that will lead to improved performance.

In the final session of this course, participants will put what they have learned into practice. Participants will analyze a new data set, rate the bank’s performance and suggest strategic adjustments that might benefit the bank.

Details & Registration

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2026 GSBC Annual School Session

July 19-31, 2026 | University of Colorado Boulder

Secure your spot now to begin in July

The Annual School Session offers a comprehensive, multi-year educational experience for community banking professionals. Students attend three consecutive annual two-week sessions at CU Boulder, with coursework that is regularly updated to address the most relevant topics facing the industry today. Participants also benefit from extensive networking opportunities with bankers from their state and across the country.

Admission & Fees

Additional information about all GSBC community banking-focused programs is available at www.GSBColorado.org. Please feel free to reach out if you need copy formatted specifically for your publication.

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Online Education

Participating in learning opportunities outside the bank can be challenging. Take advantage of the SDBA's extensive selection of webinars and on-demand training to enhance your banking expertise directly from your computer.

GSB Online Seminars
OnCourse Learning
SBS Institute
ABA Training

Learn how to put compliance management solutions from Compliance Alliance to work for your bank, by contacting (888) 353-3933 or [email protected] and ask for our Membership Team. For timely compliance updates, subscribe to Bankers Alliance’s email newsletters.