Pub. 8 2017 Issue 2

www.wvbankers.org 26 West Virginia Banker basics of its regulatory requirement. Now, executives need to know specifics when it comes time for a CRA performance evaluation. Prepare With data as king, the old “shoe box” approach will not work to effectively formulate your institution’s response for the next examination. In short, you cannot wait until the exami- nation notification to begin your preparation. Building on your momentum to dependably review and analyze your CRA data, the ability to effectively prepare for your next examination is not difficult. Simply start with your policies and procedures. If you do not have policies and procedures specific to CRA, take the time to create. If you do, take time to review those items to ensure they are operative, based on any business changes since your last examination. Not to sound like a broken record, but maintaining your performance context file is paramount to any examination prep. The context file affords the institution the opportu- nity to provide a true situational analysis regarding its CRA performance. At a minimum, commit to secondary research data collection which may utilized in performance context development. For example, examiners specifically request “economic and demographic analyses.” In addition to any details the Bank’s marketing department might be able to provide, there are many available resources one can obtain to successfully maintain the context file. In West Virginia, the WVU College of Business & Economics Bureau for Business and Econom- ic Research (WVU BBER) annually publishes an economic outlook analysis for the State of West Virginia. This data which is available online (http://business.wvu.edu/centers/bu- reau-of-business-and-economic-research/economic-outlook ) also provides analysis of specific industries and key regions. Further, the WVU BBER also offers its Mountain State Busi- ness Index, which it publishes quarterly. These resources can also be utilized to note an expected economic downturn or even defend a branching strategy in a specific area. The commitment to gathering this information will ensure the story of the institution’s performance is effectively told during the exam. Train Banks are no stranger to need for effective training. The same is the case for CRA. Remember, CRA was enacted to ensure banks meet the needs of their communities, including low- and moderate-income neighborhoods. This is not a task designated solely for the CEO or the CRA Officer. This is a mandate at every level. Dedicated CRA training will ensure employees understand the Bank’s commitment to CRA and serving local communi- ties, while also understanding – truly understanding – what qualifies under CRA regulations. It is not okay to assume when it comes to CRA. Just because an area may appear “poor” by your standards, does not mean it is an automatic low- or moderate-income area. If your employees know how to simply utilize the free CRA tools available at the FFIEC (Federal Financial Institutions Examination Council) they can better contribute to the bank’s CRA performance by under- standing how to analyze the areas you serve. Make annual training part of your overall commitment to CRA and not just a training task you check off a list. Repeat Finally, take the time to repeat. Be vigilant in your approach to CRA. After all, managing an effective CRA program re- quires commitment, and not just at exam time.  Aly is Managing Director for GuardianBridge, a boutique business services firm that supports the complex needs of business leaders and their teams to develop and implement strategies, plans, and programs to ensure business success. She also serves as Managing Partner for Bank Partnership, an initiative of GuardianBridge which provides programs and solutions to specifically help community banks, and small to medium-size regional banks, manage communications, regulatory examination risks and preparation to deliver strong results for clients and stakeholders. She can be reached at AGregg@GuardianBridge.com or (304)-549-5092. William Ihlenfeld, Patricia Kipnis and JonathanMarshall are litigation partners at Bailey & Glasser LLP, which offers corporate clients assistance in all aspects of cyberattack preventionand response.Mr. Ihlenfeldwas theUnited States Attorney for theNorthern District of West Virginia between 2010 and 2016, where he created and led a unit that investigated cyberattacks on businesses and individuals.  Gut Check Time Continued from Page 24  Cybersecurity Continued from Page 25 William Ihlenfeld Patricia Kipnis Jonathan Marshall 3. Respond to any cybersecurity incidents, in consultation as appropriate with authorities, experts, insurance attor- neys, and public relations professionals; and 4. Represent clients in government proceedings or litigation in connection with any incidents. Cybersecurity attorneys will be aware of the latest privacy regulations, cybersecurity threats and best practices to combat them. The right counsel can ensure compliance with not only legal mandates, but best practices that may not be legally required.  Summer 2017 27 West Virginia Banker Bank Notes Clear Mountain Bank Kim Dobrzynski recent- ly joined Clear Moun- tain Bank as its director of marketing. In her position, Dobrzynski will be responsible for overseeing all aspects of the marketing, adver- tising and public relations functions for the bank and its branch locations. She brings to the banks more than 17 years of experience in marketing, advertising, public relations and event planning. A native of New Jersey, she has relocated to Preston County. Ohio Valley Bank Jay Miller was recent- ly promoted to Vice President, Business Development Officer of Ohio Valley Bank. He will continue serving customers from the Bank’s offices in the Huntington area. Premier Bank Premier Bank recently announcement with addition of three veteran bankers to the bank’s Central WV Division. Sam Gallo was named Executive Vice Pres- ident and Division President. He was previously Market President for Harrison and Marion counties with MVB Bank. Mr. Gallo began his banking career in 1997 with Huntington National Bank as a Personal Banker and rose to increas- ing levels of responsibility within the company. Michael Malfregeot joined Premier as Vice President/Branch Manager and Small Business and Retail Development Man- ager. He will manage the Bridgeport office. Previously, Michael was a VP – Retail/ Small Business Development Officer and Manager with MVB Bank, where he managed the Bridgeport and Clarks- burg offices. Chris Parr has joined the bank as Vice Pres- ident and Commercial Loan Officer. Pre- viously, he was Vice President of Retail and Small Business Development for MVB Bank. Chris also began his banking career at Huntington National Bank as a Personal Banker, later, promoted to Vice President and Branch Manager.  Arnett Carbis Toothman.......................................... 31 ATM Solutions............................................................ 24 Bankers Bank Kentucky.............................................. 2 Boenning & Scattergood........................................ 20 Bowles Rice................................................................... 3 The Greenbrier........................................................... 25 Lewis Glasser Casey & Rollins.................................. 9 Smith Elliott Kearns & Company, LLC.................... 7 Snodgrass.................................................................. 29 Spilman Thomas & Battle....................................... 32 Suttle & Stalnaker....................................................... 5 WVBA Insurance Group.......................................... 17 Zeno, Pockl, Lilly and Copeland............................ 21 Advertiser Index