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Artificial intelligence is becoming a priority across financial institutions, with growing pressure from boards and leadership teams to move from exploration to implementation. While the industry continues to highlight AI’s potential, the real challenge is operational. Financial institutions are not struggling to find use cases. They are struggling to determine which ones they can confidently implement and stand behind in a regulated environment.

This session focuses on how community banks and credit unions are actually approaching AI adoption today, where implementation is gaining traction, and why some initiatives move forward while others stall. We will examine how institutions are evaluating AI through the lens of explainability, governance, and risk, and what that means for day-to-day decision-making in lending, fraud, and compliance.

You will learn:

Shift toward trade-based business is a good thing for CFIs

AI is starting to influence career choices, and recent reporting suggests a growing number of young adults are moving away from white-collar tracks and toward skilled trades they see as more resilient. This shift could lead to more startups, more independent contractors, and more equipment-heavy Main Street businesses. For community financial institutions, that is a signal to look more closely at trade-based business lending.

Simpler processes for greater performance.

Equipment leasing software

The new generation of business owners

A Harvard Kennedy School survey found 59% of 18- to 29-year-olds view AI as a threat to their careers, while employment for young adults in AI-exposed jobs has fallen 16%. The same report said vocational-based community college enrollment has risen nearly 20% since 2020. NPR reporting has pointed in the same direction, describing a “toolbelt generation” and rising interest in vocational paths tied to HVAC, electrical, and wind-turbine work.

When more electricians, plumbers, HVAC technicians, welders, and contractors enter the market, one of their first steps is often equipment financing: a truck, a trailer, a compressor, a lift, or a set of specialized tools that allows them to take on jobs and bill customers. The bank or credit union that can engage a trade-based business customer is financing the machinery behind a revenue stream.

The Bureau of Labor Statistics projects that electricians will grow 9% from 2024 to 2034, heating, air conditioning, and refrigeration mechanics and installers will grow 8%, and plumbers, pipefitters, and steamfitters will grow 4%. Overall employment in installation, maintenance, and repair occupations is projected to grow faster than average over the decade.

Why equipment finance fits the borrower profile

For banks, trade-based business lending is especially attractive because equipment finance ties the credit decision to a tangible, income-producing asset. A truck, trailer, skid steer, or commercial HVAC unit does more than sit on a balance sheet; it helps the borrower generate the revenue that supports repayment. That gives lenders a financing structure that matches the way the business actually operates.

Equipment lending is often a better fit than a generic unsecured loan. Many newer trade businesses do not need broad corporate borrowing capacity on day one, but they do need the specific asset that helps them complete jobs, take on larger contracts, and move faster than their competition. A financing program built around the equipment purchase can meet that need without forcing the borrower into the wrong product.

Moving early to stay ahead

Banks that update underwriting, documentation, and product design to support this growing pool of borrowers will be a step ahead of their competitors. The first institution to build trust with a new contractor or small trade owner is often the one that gets the next request for a line of credit, a deposit account, treasury services, or a second piece of equipment.

Instead of chasing a trend, trade-based business lending is a strategic way to align the balance sheet with where the next generation of business owners is likely to emerge. As more young workers choose trades that feel stable in an AI-shaped economy, banks that understand the borrower’s tools, cash flow, and growth path will be better positioned to serve them.

Next steps for community financial institutions

The moral of the story is that AI is changing where people see opportunity. Some of that opportunity is moving into the trades, creating a pipeline of borrowers who are more asset-dependent, more local, and more relationship-driven than many banks and credit unions may expect.

AI is also speeding up financial institutions' workflows and changing borrowers' expectations regarding speed and digital capabilities. Modernizing their processes can keep community financial institutions competitive and help them allocate more time to personal relationships with members and customers. 

In addition to saving time and creating happier customers and partners, an automated equipment finance operation also helps the organization with:

  • Risk reduction: Automated audit trails and compliance checks reduce manual errors and documentation gaps.
  • Improved analytics: Integrated platforms centralize data across contracts, assets, and vendors—giving executives better insight into profitability, risk exposure, and performance trends.

Improve monitoring for emerging credit risks

AI improves credit risk monitoring by analyzing portfolio data in real time and helping teams quickly identify trends, exceptions, and potential risk exposures. Learn why traditional monitoring falls short late in the cycle and why modernizing processes helps with AI adoption.

A new phase for credit risk monitoring

Credit risk monitoring is entering a new phase. The fundamentals haven’t changed; sound judgment, defensible assumptions, and clear communication still matter.

But late-cycle conditions are exposing the limits of periodic, backward-looking reporting. The combination of modern data visualization and artificial intelligence (AI) offers a practical way to see emerging risk sooner, ask better questions in real time, and connect allowance work to day-to-day credit monitoring.

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Why traditional monitoring late cycle falls short

Credit risk has always been a science and an art. Institutions vary widely in their approach to credit risk modeling and monitoring. But many traditional credit risk models and processes share a common limitation: they rely on periodic data pulls, “black box” third-party models, and static assumptions. And in many cases, analysis is limited to retrospective/historical review.

Processes that rely entirely on past loss rates, monthly delinquency positions, and/or instrument-level probabilities of default (PDs) from a third party that haven’t been backtested against your own experience or that of named peers are increasingly insufficient this late into a credit cycle.

There are real advantages to evaluating or re-evaluating your approach to credit monitoring and adjacent process in the current environment. AI and modern visualization tools can help leadership charged with managing and monitoring credit risk by providing real-time data and trends, relevant industry data, and consolidating inputs and outputs from critical models such as allowance, stress testing, ALM, and deposit-related tools.

 

Moving beyond allowance in a vacuum

The allowance is the one area of credit modeling that directly impacts financial statements. The process is subject to external audit and examination. For these reasons alone, it’s common for institutions to modernize the process. As we all know, some choices can have a cascading effect throughout an organization, and this area is one of them.

When the allowance is managed in a spreadsheet or in a vacuum, the exercise becomes one of data entry, simple historical loss rates, storage, filed away spreadsheets, and canned reports. It becomes challenging to communicate inputs, assumptions, and results to anyone within the organization removed from the actual creation of the “answer.” To simply view output trends becomes a time-consuming exercise for everyone involved.

There are also approaches that may seem advanced, such as some third-party provided PD and LGD that haven’t even been backtested against your own experience, but they can’t be audited/reviewed. Nor can the default rates be explained by leadership. This severely limits the value of the entire process and leadership’s ability to let the allowance process become an integral part of credit risk monitoring.

Modernizing processes yields data accessibility

As leadership thinks about AI, it’s important to consider that one critical step in realizing the benefits is to begin modernizing processes in such a way that the inputs and outputs to key processes are accessible. For example, if the allowance is designed thoughtfully and not isolated to a spreadsheet environment or the result of a black box model, anyone in management could, at any moment and without request, observe through real-time visualization tools the following key allowance and credit monitoring trends:

  • Segment-level allowance level trends (obvious)
  • Segment-level realized default rate trends relative to default rate assumptions used in the allowance
  • Various economic scenarios and resulting segment-level allowance levels and underlying default rate expectations
  • Allowance change attribution (drivers of change – balance, forecast, qualitative, etc.)
  • Input and assumption trends
  • Qualitative factor allocation trends
  • Relevant industry data and trends for relativity (coverage ratios, default rates, loss rates, loan growth, etc.)

That visibility can turn the allowance from a quarterly (or monthly) output into an always-on monitoring lens—one that leadership can review, discuss, and challenge without waiting on a report run.

On top of yielding real-time visualization, communication, and quality of the output, the organization of inputs, assumptions, and underlying data enables financial institutions to now experience real benefits from AI. It is no longer a difficult lift and paves the way to move beyond theory and into tangible benefits.

What AI looks like in day-to-day credit risk management

two people reviewing financials on a tabletLet’s take the above example one step further. While viewing the real-time data, anyone in management may see something that stands out to them and prompt AI to “list all of the loans that have downgraded between December and March” or “summarize all delinquencies in Commercial by industry code.” The point: you can now react to what the data is showing with instant answers, without data pulls, spreadsheets, or difficult-to-communicate requests to others in the organization.

Once that foundation is in place, AI stops being theoretical and becomes usable, starting with simple, high-value questions that connect what you’re seeing to what needs attention.

 

Real-time portfolio and concentration monitoring

CRE exposures, relationship concentrations, geographic risks, loan-structure anomalies, exception tracking, and borrower-level stress are just a few examples of rapidly evolving items that may require frequent threshold mapping, tracking, and monitoring.

Traditional reporting can be time-bound (periodic) and relatively rigid, often proving difficult or requiring custom work to drill down into the details. AI-powered monitoring systems can not only track concentrations continuously but also allow user interaction in a way that wasn’t possible without report-writing skills or specific requests of those with report-writing skills. They allow users not only to drill down into the underlying data, but also to ask questions beyond the data shown.

For risk and finance teams, AI-powered environments offer new time-saving abilities and avenues of understanding. Imagine you’re reviewing your daily dashboard, specifically, utilization, and you notice it’s increasing beyond historical trends. You prompt, “list the loans with the largest increase in utilization with a 6-month trend of their respective days past due.” You notice that a few loans with increasing utilization have gone from zero to 5,10, or 15 days past due. AI then asks you, “Would you like this to be included in your dashboard in the future?”

You’ve avoided pulling 6 months of loan files, organizing data, and writing formulas in a spreadsheet (or requesting that someone else do this). Instead, you get immediate information and have improved the shared dashboard for others in your organization. Just as important, this approach helps teams move upstream—spotting patterns that often show up before delinquency forces the conversation.

When it comes to borrower-level stress, it generally, doesn’t appear overnight. Often, there are subtle changes early on:

  • Slower prepayment patterns
  • Higher/increasing utilization
  • Industry performance decline (external data)
  • Economic pressures
  • Deposit/cash depletion

Instead of waiting for delinquency metrics to materialize, AI provides efficient ways to identify potential trends and research their specifics before taking action. Ultimately, this type of monitoring strategy improves mitigation options.

Judgment remains central; AI strengthens it

Mature woman and young man reviewing documentsCredit risk management still requires experienced practitioners to interpret results, challenge assumptions/recommendations, and to consider qualitative information in decision-making. AI can efficiently provide information in a way that offers visibility, clarity, and insight into current and emerging risk patterns.

Institutions that choose to silo important credit risk functions into spreadsheets, black box third-party tools, and/or stagnant software risk falling behind. There must be a credible path for AI to, in real time, access inputs, outputs, and peripheral data in order to realize tangible benefits.

For leadership, the objective remains similar. Lead your teams with vision. Produce reliable and defensible channels of information. Efficiently (or autonomously) distribute the information so that everyone is making decisions with similar and sound knowledge. AI simply provides a more efficient and powerful set of tools to achieve that objective.

Adopt AI with confidence and control. Abrigo Advisory Services can help.

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FAQs

What is AI in credit risk management?

AI in credit risk management uses advanced analytics and natural language interaction to help financial institutions monitor portfolio performance, identify emerging risks, and analyze large volumes of credit data more efficiently. It supports decision-making by providing faster access to insights while keeping human judgment at the center.

How does AI improve credit risk monitoring?

AI improves credit risk monitoring by analyzing portfolio data in real time and helping teams quickly identify trends, exceptions, and potential risk exposures. This allows institutions to investigate issues sooner instead of relying solely on periodic reports and historical performance reviews.

Why are traditional credit risk monitoring methods becoming less effective?

Traditional monitoring approaches often rely on static reports, historical loss data, and periodic reviews that may not capture changing risk conditions quickly enough. In a late-cycle environment, emerging risks can develop between reporting periods, reducing visibility and delaying response times.

How can AI help identify emerging borrower stress?

AI can help detect early warning indicators such as increasing credit utilization, declining industry performance, reduced deposit balances, and changing payment behavior. Identifying these signals before delinquency occurs gives institutions more time to evaluate and mitigate potential credit risks.

What role does data accessibility play in successful AI adoption?

Data accessibility is a foundational requirement for effective AI implementation. When credit risk, allowance, and portfolio data are centralized and readily available, AI tools can generate meaningful insights, answer questions quickly, and support real-time monitoring across the organization.

Can AI replace human judgment in credit risk decisions?

No. AI is designed to enhance, not replace, human expertise. Credit professionals remain responsible for interpreting results, challenging assumptions, incorporating qualitative factors, and making sound risk management decisions based on a complete understanding of the institution's portfolio.

Leadership shapes every aspect of BSA management—from front-line alerts to boardroom decisions. Yet while leadership is often emphasized, followership is frequently overlooked. Effective leadership is not one-directional; it depends on how people receive, interpret, and respond to guidance.

This session explores leadership through the lens of followership, examining how follower styles influence outcomes, how trust and accountability are co-created, and why self-awareness as a follower is essential to becoming a stronger leader. Grounded in leadership theory and practical application, the webinar will provide actionable strategies you can apply whether you’re influencing from the front lines or guiding executive decisions.

Key takeaways

This session is best for program and team managers and Vice Presidents.

The changing environment affects deal pricing and fair value outcomes

Over the past two years, the M&A landscape for financial institutions has undergone a meaningful transition. A previously constrained environment was defined by rapidly rising interest rates, widening valuation discounts, muted deal activity, and a lengthy regulatory process. That environment has now become more constructive and more active, creating a wider window for transactions and changing the assumptions that drive fair value. 

As rates, funding costs, approval timelines, and purchase accounting have shifted, fair value outcomes have become less punitive in some areas and easier to model with greater confidence.

Read the latest on loan fair value and exit price trends.

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Factors affecting fair value marks

Rising and elevated market rates drove significant pressure on loan fair value marks while also increasing the value of core deposits in recent years. But several more recent key developments altered that dynamic and accelerated the announcement of merger transactions in 2025:

  • The Federal Reserve has shifted policy direction, implementing rate cuts following peak tightening
  • Market expectations for future rate paths have stabilized
  • Bank loan portfolios have repriced upward
  • Bank equity valuations have improved
  • Regulatory processes have become more efficient
  • Deal flow has begun to reaccelerate, with a broader mix of transaction structures

Although deal activity has slowed into 2026, this updated environment is changing not only how deals are priced, but also how fair value is measured and interpreted. Transaction-specific analysis remains critical for financial institutions, even in a more constructive environment, because portfolio composition, borrower concentration, collateral trends, and embedded risks can still materially affect deal economics.

A reopening M&A window

During the rising rate cycle, deal activity slowed considerably due to:

  • Depressed bank stock valuations
  • Increased uncertainty around credit quality
  • Larger fair value discounts, particularly on fixed-rate loan portfolios
  • Tangible book value dilution concerns

Today, many of those handicaps have partially reversed. Lower rates, improved market confidence, and the regulatory backdrop have:

  • Reduced the severity of loan discounts
  • Improved buyer currency (stock)
  • Increased alignment between buyer and seller expectations
  • Reduced execution risk through shorter approval timelines

As a result, we are seeing more traditional acquisitions returning, including the re-emergence of large transactions. We are also seeing increased competition for attractive franchises, particularly those with strong deposit bases. Shorter deal timelines further reduce the risk that fair value estimates will change materially between announcement and closing.

Loan portfolio valuations: From peak discounts to normalization

At the peak of the rate cycle, loan portfolios experienced significant fair value discounts driven by:

  • Market discount rates far exceeding portfolio yields
  • Limited ability for legacy loans to reprice
  • Elevated uncertainty around borrower performance

The Federal funds rate reached a peak in mid-2023 and held flat for much of 2024. Beginning in September 2024, the Federal Reserve reduced rates, bringing the year-end 2024 federal funds rate to 4.33%. Rates then stabilized through most of 2025 until the Federal Reserve resumed easing in September 2025, cutting rates by another 75 basis points over three moves by year-end. As the yield curve began to normalize, loan portfolio yield discounts also compressed meaningfully.

While market rates remained elevated relative to 2020 and 2021 levels, cumulative Fed easing since the third quarter of 2024, combined with continued repricing of loan portfolios toward current market levels, reduced the severity of yield-driven discounts reflected in the accounting for loans.

With rate stabilization and selective rate cuts:

  • The spread between market rates and portfolio yields has generally narrowed
  • New loan production and variable rate loan repricings have lifted portfolio yields overall
  • Discount severity has moderated meaningfully

Financial institutions with older fixed-rate loans with longer maturities, however, remain more challenged from a fair value perspective.

Credit marks: Stability, with continued need for diligence

Credit marks remained relatively stable through much of the rate cycle, as macroeconomic conditions held up better than expected. That stability, however, should not be read as a reason for less rigorous diligence.

Aggregate credit marks may appear steady, but portfolio composition, borrower concentration, collateral trends, and pockets of embedded risk can still materially affect deal economics.

Core deposit intangible values: Peak value from higher rates has passed

In a rising rate environment, core deposits became more valuable as the spread between low-cost deposits and alternative funding sources widened. That dynamic increased the value of core deposit intangibles and made strong deposit franchises more attractive in M&A transactions.

As rates have declined, the economic advantage of core deposits has compressed modestly because the cost of alternative funding sources has also decreased. The spread between the all-in cost of core deposits and wholesale funds has narrowed, reducing some of the premium that higher-rate conditions created.

Core deposits remain an important source of franchise value, but the tradeoff in valuation is worth noting. Higher CDI values reduce goodwill, which does not amortize, while also increasing future noninterest expense through CDI amortization. As CDI values moderate, that future amortization burden becomes somewhat less of a concern for buyers evaluating transaction economics.

CECL and purchase accounting: Complexity has been simplified

The interaction between fair value marks and CECL remains a central issue in deal modeling. In November of 2025, the FASB adopted ASU 2025-08 (Topic 326) for the accounting of purchased credit deteriorated (PCD) loans and non-PCD loans (now referred to as purchased seasoned loans or PSL). The change eliminates the prior “double count” impact and simplifies how institutions model the effect of acquired loan marks.

Under the prior standard, an institution determined the fair value of the acquired loan portfolio and recorded the discount on Day 1, which increases goodwill. After closing, the institution then immediately recorded an allowance on non-PCD loans through provision expense. In effect, a portion of the credit mark was counted twice, once in fair value and again through the allowance.

Under the new standard, PSL loans receive the same accounting treatment as PCD loans, eliminating the double count. The change improves Day 1 capital because an immediate provision expense no longer reduces retained earnings. Instead, a portion of the mark is reallocated to the allowance at closing.

That benefit comes with an important tradeoff. Because a portion of the discount related to non-PCD (PSL) loans is now allocated to the allowance rather than accreted into income over time, income accretion will be lower than under the prior model. For acquirers, the result is a cleaner, more transparent framework for evaluating capital, goodwill, and post-close earnings impact.

Faster approvals: Implications for fair value

One of the more meaningful shifts in today’s environment is the acceleration of regulatory approvals.

Historically, transactions often took four to six months (and longer for more complex deals) from announcement to closing. As such, there was market risk that fair values could change materially before close, particularly in volatile rate environments.

The risk was especially evident in 2023, when rising rates widened loan fair value discounts rapidly while portfolio yields adjusted more slowly. In some cases, the estimated loan discount at due diligence differed significantly from the amount ultimately booked at closing, resulting in higher goodwill than initially anticipated, all else equal.

Shorter windows from announcement to closing reduce some of this risk in today’s market. For buyers and sellers, that means greater confidence that the fair value assumptions used to evaluate a transaction will remain relevant through closing. It also improves the reliability of early-state deal modeling and reduces the likelihood that transaction economics will shift materially late in the process.

A changing M&A market  requires discipline

The current M&A environment represents a transition from constraint to opportunity.

Many of the pressures from the rising rate cycle have eased. Loan discount severity has moderated, bank valuations have improved, and approval timelines have shortened. At the same time, changes in purchase accounting have simplified one of the more complex elements of deal modeling.

Even so, fair value remains highly sensitive to assumptions for both the interest rate component and the credit component. Core deposit intangible values have decreased and stabilized, reducing concern for buyers’ future amortization expense levels, but they remain an important part of franchise value in many transactions.

The result is a more active deal environment than a few years ago, but not a simpler one. Evaluating transaction economics in financial institution acquisitions or mergers requires disciplined valuation frameworks, forward-looking macro assumptions, and granular portfolio analytics. Early-stage due diligence fair value analysis also remains essential to gauge deal economics. Finally, the interaction between valuation and CECL continues to require careful consideration under the new FASB treatment for PCD and PSL loans.

FAQ

What is fair value in bank M&A?

Fair value in bank M&A is the estimated market-based value of acquired assets and liabilities at the transaction date. For banks, fair value analysis often focuses on acquired loan portfolios, core deposit intangibles, credit marks, interest rate marks, goodwill, and post-close earnings impact. Abrigo supports financial institutions with CECL, purchase accounting, and portfolio risk tools that help make bank M&A fair value analysis more structured and defensible.

How have interest rates changed fair value outcomes in bank acquisitions?

Interest rates have changed fair value outcomes by reducing some of the severe loan discounts seen during the rising-rate cycle. As market rates stabilized and portfolios repriced closer to current yields, loan fair value discounts became less punitive, although older fixed-rate loans with longer maturities may still face valuation pressure. Abrigo helps banks evaluate these assumptions through fair value, CECL, and portfolio risk analysis.

Why do credit marks still matter in bank M&A?

Credit marks still matter in bank M&A because aggregate credit conditions can look stable while specific borrower concentrations, collateral trends, or embedded risks affect deal economics. A disciplined fair value process reviews both interest rate marks and credit marks before closing. Abrigo’s credit risk and purchase accounting solutions help banks evaluate acquired loan portfolios with greater consistency.

How do core deposit intangibles affect bank acquisition pricing?

Core deposit intangibles affect bank acquisition pricing by assigning value to stable, low-cost deposit relationships acquired in a transaction. As rates have declined, the advantage of core deposits over alternative funding has narrowed, which can reduce CDI values and future amortization expense. Abrigo helps banks analyze deposit franchise value as part of broader bank M&A fair value modeling.

How did CECL changes simplify purchase accounting for bank M&A?

CECL changes simplified purchase accounting by reducing the prior “double count” effect for acquired loans. Under FASB ASU 2025-08, purchased seasoned loans receive accounting treatment similar to purchased credit deteriorated loans, which improves Day 1 capital treatment but may reduce future income accretion. Abrigo supports CECL software for banks and purchase accounting workflows that help finance teams model these tradeoffs.

Abrigo has deep valuation and bank purchase accounting expertise. We provide accurate and timely fair value and income recognition services for financial institutions.

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What the Q1 2026 ACH metrics mean for ACH fraud detection

The ACH Network entered 2026 with strong momentum as financial institutions continue to modernize payments. Newly released metrics from Nacha show accelerating adoption of Same Day ACH and continued growth in business-to-business (B2B) payments—two trends that are reshaping the payments landscape for banks and credit unions alike.

Key topics covered in this post: 

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Same Day ACH growth continues to accelerate 

The Q1 Nacha numbers reflect changing customer expectations around real-time payments, increasing pressure to modernize ACH fraud detection strategies, and the need to adapt to an evolving regulatory and operational environment. 

According to Nacha, there were 403 million Same Day ACH payments in the first quarter of 2026, representing a 23.6% increase over the same period last year. The value of those payments reached $1.1 trillion, up 22.1% year over year and marking the second consecutive quarter that Same Day ACH value surpassed the $1 trillion threshold. 

This sustained growth should signal to community financial institutions that faster payments are no longer viewed as a premium or niche service. Businesses and consumers increasingly expect funds to move quickly, predictably, and securely. With these expectations, ACH operations can no longer be treated as purely back-office functions. ACH has become a strategic channel directly tied to customer experience and competitiveness. Many institutions are evaluating how Same Day ACH complements broader, faster payments strategies while maintaining operational resiliency and compliance. 

B2B payments are driving ACH network expansion 

Nacha also reported that nearly 2.1 billion B2B payments moved through the ACH Network during Q1, an increase of 9.4% compared to a year ago. These numbers reinforce a broader industry shift away from paper checks and manual payment processes. Commercial customers increasingly want digital payment experiences that improve cash flow visibility and reduce processing delays. 

For banks and credit unions, B2B ACH growth creates opportunities to deepen treasury relationships and deliver more value-added services. At the same time, commercial ACH activity can introduce elevated fraud risks due to higher transaction values and increasingly sophisticated fraud tactics. This is where ACH fraud detection becomes especially critical. 

Faster payments increase the need for strong ACH fraud detection 

As payment speed increases, fraud decisioning windows shrink. Financial institutions have less time to identify suspicious activity before funds move. Fraudsters understand this dynamic and increasingly target ACH channels using account takeover schemes, business email compromise, synthetic identities, and mule account activity. 

The continued rise of Same Day ACH means institutions need fraud controls that can operate in near real time without creating unnecessary friction for legitimate customers. Modern ACH fraud detection solutions increasingly rely on layered approaches that combine behavioral analytics, anomaly detection, risk scoring, and ongoing transaction monitoring. Institutions also need visibility across payment channels, since fraud patterns rarely remain confined to a single rail. 

The challenge is balancing speed with security. Customers expect payments to move faster, but they also expect their financial institution to protect them from fraud. According to survey data from Abrigo, the majority (51%) of American respondents aged 25 to 34 believe banks should always reimburse fraud victims. 

What financial institutions should prioritize next 

As ACH usage moves into faster, higher-value payment scenarios, expectations for financial institutions’ governance, risk management, and fraud prevention will grow accordingly. Financial institutions are increasingly evaluating whether existing processes, staffing models, and technologies are equipped to support the growing volume and velocity of transactions. 

The Q1 2026 ACH metrics point to several priorities for banks and credit unions: 

  • Strengthening ACH fraud detection capabilities to support faster payment environments  
  • Improving visibility into high-risk transaction behavior  
  • Supporting commercial clients transitioning away from checks  
  • Balancing payment speed with risk management and compliance expectations  

The ACH Network remains one of the foundational payment rails in the U.S. financial system, but the way institutions use it is changing rapidly. For financial institutions, the message from Q1 is clear: ACH modernization is no longer optional. It is now central to how institutions compete, protect customers, and support the future of digital payments. 

Large sporting events like the FIFA World Cup can exacerbate human trafficking

The upcoming 2026 FIFA World Cup brings excitement for soccer fans around the globe, but for financial institutions and law enforcement, major sporting events also signal the need for heightened vigilance against human trafficking.

What is human trafficking?

Human trafficking is a crime in which force, fraud, or coercion is used to compel a person to perform labor, services, or commercial sex acts. Large-scale events often create increased demand for temporary labor, hospitality services, transportation, and commercial sex, creating opportunities for traffickers to exploit victims.

Financial institutions of all sizes play a critical role in identifying and reporting suspicious activity connected to human trafficking. According to FinCEN Director Andrea Gacki, “Timely reporting on suspicious activity potentially connected to human trafficking, regardless of threshold, is crucial in helping law enforcement aid possible victims and prosecute their traffickers.”

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Notice urging financial institutions in and around cities hosting the 2026 FIFA World Cup to increase vigilance. The 2026 FIFA World Cup is expected to draw millions of domestic and international visitors, and financial institutions of all sizes play a pivotal role in detecting and reporting suspicious activity related to human smuggling and human trafficking.

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Behavioral indicators and transactional red flags

Behavioral red flags may include the presence of a controlling third party who:

  • Speaks on behalf of the customer
  • Insists on remaining present throughout the interaction
  • Attempts to complete paperwork without consulting the customer
  • Retains possession of the customer’s documents or funds
  • Behaves aggressively or intimidates the customer

Additional warning signs may include customers who:

  • Appear malnourished, fatigued, or show signs of abuse
  • Do not know where they are staying or provide inconsistent stories
  • Show little control over their own finances or personal documents

Sex trafficking during major events

FinCEN notes that victims of sex trafficking may be forced to travel frequently to meet clients within short timeframes. As a result, victims or traffickers may exhibit unusually large travel-related transactions. Victims often receive payment for commercial sex acts in cash, but traffickers may also use peer-to-peer transfers, credit card payments, digital assets, or prepaid access cards.

Other transactional red flags include:

  • Frequent cash deposits into easily accessible ATMs
  • Rapid transfers of deposited funds to another account
  • Transactions inconsistent with a customer’s normal activity patterns

Labor trafficking during major events

The increased demand for labor and services surrounding major sporting events can also create opportunities for labor trafficking.

Seemingly legitimate businesses in host cities may use exploitative employment practices to meet staffing demands. Financial institutions may observe:

  • An absence or deviation from expected payroll expenses
  • Wages transferred from a victim’s account to another individual’s account
  • Large deductions from employee wages
  • Minimal or no transactions associated with maintaining essential living needs, which may indicate a trafficker’s financial control over a victim

Financial institutions are key partners in combating human trafficking

According to the National Human Trafficking Hotline, working in the financial industry provides you the opportunity to report suspicious behavior involving 92% of the various types of human trafficking. When you encounter transactions that just don’t feel right, don’t hesitate to file Suspicious Activity Reports (SARs) and call the National Human Trafficking hotline at 888-373-7888.

FinCEN also encourages voluntary information sharing among financial institutions and financial institution associations, including appropriate cross-border sharing with foreign financial institutions, to help identify and prevent potential money laundering or other illicit activity related to human trafficking.

Customer-facing employees are especially important in identifying potential trafficking activity because victims may have limited contact with people outside of their traffickers, other than when visiting financial institutions.

It's easy to feel overwhelmed by the number of potential human trafficking transactions you find, knowing the abuse that lies behind these transactions. The good news is there are data scientists designing ways to detect these patterns without human intervention. Financial institutions with AML software that incorporates AI will be empowered to find data that can free victims faster.

Learn more human trafficking behavioral indicators with this checklist: "Human Trafficking Red Flags."

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The risk of outdated technology and processes

Some financial institutions look efficient on paper but have outdated processes and technology systems. These can reveal gaps in compliance, data integrity, or risk controls. Misclassified borrowers, inconsistent data, and incomplete information lead to flawed decisions.

'Business as usual' no longer works 

My introduction to banking came in a small hometown institution, working summers between college years. Back then, the industry (only half-jokingly) ran on the “3-6-3” rule: pay 3% on deposits, charge 6% on loans, and be on the golf course by 3:00—especially on Thursdays where I worked. 

Those days are gone. Margins are tighter, competition is faster, and borrowers have more options than ever. “Business as usual” no longer works. 

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3 Outdated modes of operation

Underwriting

Early in my career, underwriting involved paper, pencils, and a good typewriter ribbon—and it took days. Today, we have automated loan origination systems…and it still takes days.

No amount of technology will fix an obsolete, overly complex underwriting approach. Meanwhile, fintechs offer decisions in minutes and funding within a day. You can debate their philosophy, but your borrowers won’t. They care about speed and certainty. And they will pay for it.

The contrast to lending at many financial institutions is stark: a straightforward credit that could be decisioned in hours instead moves through days of rework, duplication, and handoffs.

Risk isn’t one-size-fits-all, yet we treat it that way. Simple credits should move quickly and consistently. Time and expertise should be reserved for complex risk, where it actually matters.

Approvals

In response to past failures, the industry swung from excessive approval autonomy to excessive control. The result: layered approvals, diffused accountability, and slow decisions.

Recent data shows most institutions still require three or more approval levels for small business credit. That is a process choice with consequences, and in most cases, the process choice isn’t about risk management; it’s risk avoidance.

Not every exposure deserves the same treatment. A small loan that cannot threaten the institution should not be subjected to the same process as a top-tier exposure.

Put this in perspective. Stack rank your loan portfolio by smallest borrower to largest. How much of your portfolio exposure is represented by 50% of your borrowers?  60%? 70%? 80%? I suspect that 70% to 80% of your borrowers combined represent a fraction of your portfolio. Why do you want to spend so much time and effort approving facilities to them when, if you charged off the whole segment (which is highly unlikely given the diversity), you can’t lose your institution?

If you want people to manage risk, give them ownership and make them accountable. Use portfolio tools to identify outliers. Stop treating every loan like your worst-case scenario requiring elevated approvals.

Technology and data

We depreciate software over 3–5 years yet hesitate to invest in modern systems, especially core platforms. Instead, we build workarounds.

The result is a patchwork of spreadsheets—isolated, inconsistent, and poorly governed. Meanwhile, we still insist the core is the “single source of truth,” even when it clearly isn’t.

Worse, we launch products we can’t operationally support. That leads to manual processes, shadow systems, and sometimes even Post-it notes backing what we often market as automated capabilities. Critical data lives outside the system of record and is reconciled manually.

Core replacement is expensive and disruptive. But avoiding it comes with its own cost: inefficiency, errors, and a slow bleed of resources.

Hidden costs = credit costs

There are institutions that look efficient on paper, only to later reveal gaps in compliance, data integrity, or risk controls. Efficiency ratios can mask underlying fragility.

If you don’t trust your data, you can’t manage your portfolio. Misclassified borrowers, inconsistent data, and incomplete information lead to flawed decisions.

If your institution is slow, process-heavy, and reliant on backward-looking metrics because that’s all you have, you have a credit problem, whether you recognize it or not.

The path to closing innovation gaps

In the effort to avoid risk (as opposed to manage it), the result is often an elevated risk profile due to inefficiency, ignorance and error. But there is a way to fix this. This isn’t easy—but it is straightforward.

Principles

Start with a clear foundation:

  • Focus on decision making speed and quality
  • Favor controlled, incremental change over reactive “big bang” efforts
  • Prioritize risk reduction over marginal productivity gains
  • Align credit culture, policy/guidance, and incentives with the desired operating model

Identify blind spots

Bring the right people (line, credit, loan servicing, CRO, CCO, CFO) into a room and dissect the credit process end-to-end. The only “sacred cow” is that there are no sacred cows. If a step exists, it should be defensible. If it isn’t, it should be challenged.

Ask simple but uncomfortable questions:

  • Why does underwriting take so long?
  • What slows approvals?
  • Where are exceptions and overrides coming from? Are they relevant to the true credit risk of the institution, or just pet peeves?
  • How are people actually spending their time?
  • Where are losses—or (more likely) excessive servicing costs—emerging?
  • Do we have the data we need? If not, why?

The goal is clarity: what prevents effective, quick, risk-based decisions?

Fix the operating model

Most efforts fail due to resistance to change rather than due to a lack of insight. Without executive and board-level alignment from the start, modernization will stall.

Focus on:

  • How time is actually spent vs. how it should be spent
  • Streamlining underwriting and eliminating low-value steps
  • Reducing unnecessary approvals
  • Clarifying accountability
  • Aligning incentives with desired behaviors

Once you go through this process and make the necessary adjustments, the next step is to ensure that your policies, guidance, and procedures (as well as the incentive program) are simplified and realigned to the new model and CLEARLY communicated to your team with plenty of time for feedback and internalization.  To simply impose change without communication and alignment is another major flashpoint of failure.

Modernize data (incrementally)

You can’t fix data all at once. But you do need to start somewhere. Pick a handful of critical credit data elements and clean them for your largest exposures. Then expand. Build processes to maintain data quality at every touchpoint, with clear points of accountability and consequences for failure.

In parallel, improve the completeness and timeliness of borrower information, also with accountability and consequences. From there, establish governance to systematically address gaps.

Progress will be incremental, but standing still is not an option.

Use technology thoughtfully

The biggest mistake institutions make when it comes to modernizing systems is layering new technology onto broken processes. Far too often, automation fails because decisions still require excessive time and effort.

Here are some key questions to address as you consider a new loan origination system or other technology:

  • What decisions can be automated?
  • Where is human judgment truly needed?
  • Are roles and responsibilities clear?
  • Is underwriting aligned with actual risk?
  • Are we identifying emerging risks early?

The role of artificial intelligence

AI is a strategy and a tool. Before financial institutions can answer “How do we use AI?” it helps to answer “What problem are we solving?”

Today, on individual credit, AI can already support:

  • Benchmarking and comparative analysis
  • Early detection of financial stress
  • More consistent underwriting decisions

At the loan portfolio level, AI can surface patterns that are very difficult to detect manually—across markets, products, or borrower types.

But AI requires discipline:

  • Clear governance by use case (underwriting, monitoring, portfolio management)
  • Defined human accountability
  • Transparency in outputs
  • Ongoing monitoring for drift and bias

AI can enhance judgment. It cannot replace responsibility.

Rethink how decisions are made

Competing today requires more than adopting new technology. It requires rethinking how decisions are made.

Better decisions—faster, more consistent, and grounded in reliable data—aren’t just an efficiency gain. They are a credit risk imperative. The most dangerous credit risks rarely announce themselves. They build quietly through slow processes, unclear accountability, and unreliable data, until they surface in ways that are harder to correct.

And yes—it’s still okay to play golf on Thursday afternoon.

You might like this webinar: "AI's impact on credit risk: What to consider in your portfolio."

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FAQ

What is credit risk management?

Credit risk management is the process banks and credit unions use to identify, measure, monitor, and control the risk that borrowers may fail to repay loans as agreed. Abrigo supports credit risk management with software that helps financial institutions strengthen underwriting, improve portfolio visibility, monitor changing borrower risk, and make more consistent credit decisions.

Why are outdated lending processes a credit risk problem?

Outdated lending processes create credit risk when slow underwriting, excessive handoffs, and inconsistent data lead to flawed or delayed decisions. Abrigo’s lending and credit risk software helps financial institutions streamline underwriting, reduce low-value steps, and focus human judgment where risk is most material.

How can banks and credit unions close innovation gaps in lending?

Banks and credit unions can close innovation gaps by reviewing the credit process end to end, eliminating unnecessary approvals, clarifying accountability, and improving critical credit data over time. Abrigo supports this modernization with risk management software for banks and credit unions that helps align technology, policy, workflow, and portfolio monitoring.

What role does data quality play in credit risk management?

Data quality is central to credit risk management because incomplete, inconsistent, or misclassified borrower information can weaken underwriting, monitoring, and portfolio decisions. Abrigo’s credit risk management software helps financial institutions improve visibility into borrower and portfolio data so teams can identify risk earlier and make better-informed decisions.

How should financial institutions use AI in credit risk management?

Financial institutions should use AI in credit risk management to support benchmarking, financial stress detection, underwriting consistency, and portfolio pattern recognition. Abrigo emphasizes that AI should enhance judgment, with clear governance, human accountability, transparency, and monitoring for drift and bias.

At first glance, a machine in a store might look like a standard Automated Teller Machine (ATM). Some are traditional ATMs that dispense cash. Others are cryptocurrency ATMs, often called Bitcoin teller machines (BTMs), that allow customers to buy or sell cryptocurrency using cash. They may share a similar name, but they operate very differently and pose distinct risks and compliance expectations for financial institutions.

As cryptocurrency adoption continues to expand, more merchants are installing BTMs to generate additional revenue. This trend makes cryptocurrency ATM monitoring an increasingly important part of a financial institution’s risk management program. During site visits and customer reviews, staff can no longer assume that every machine functions under traditional ATM rules.

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Why BTMs require closer attention

Unlike a traditional ATM, a BTM facilitates the exchange between fiat currency and cryptocurrency. This activity typically classifies the operator as a money services business (MSB), which brings added regulatory obligations under the Bank Secrecy Act (BSA) and anti-money laundering (AML) requirements.

From a risk standpoint, BTMs introduce several concerns:

  • The potential for pseudonymous transactions, depending on controls
  • Rapid movement of funds across jurisdictions
  • Increased exposure to fraud and illicit activity
  • Third-party operators with varying levels of compliance maturity

Financial institutions already understand that higher-risk products require stronger oversight. As expectations for BSA and AML programs continue to evolve, maintaining awareness and control over emerging channels, such as BTMs, is essential.

Regulatory expectations for BTM operators

Financial institutions should expect BTM operators to meet specific regulatory and compliance requirements. Gaps in these areas may indicate elevated risk.

  • Registration and licensing
    BTM operators must register as an MSB with the Financial Crimes Enforcement Network (FinCEN). Many states also require a money transmitter license or additional cryptocurrency-related licensing.
  • AML program requirements
    A compliant operator should maintain a written AML program that includes:
  • Customer identification and verification procedures
  • Ongoing transaction monitoring
  • Suspicious activity reporting
  • A designated compliance officer
  • Independent review
    Operators should conduct independent audits of their AML program and utilize appropriate monitoring procedures. These tools help identify exposure to high-risk wallets, sanctioned entities, or suspicious transaction patterns.

Banking relationships
Because BTMs require a financial institution to facilitate cash flow, the operator’s compliance posture directly impacts the bank or credit union. This underscores the importance of due diligence and ongoing oversight.

This is where cryptocurrency ATM monitoring plays a key role. Understanding who owns, operates, and manages the machine is foundational to assessing risk.

Third-party risk

A common challenge is that merchants do not always own the BTM located on their premises. In many cases, a third-party provider installs and operates the machine, and the merchant receives a share of the revenue.

This type of arrangement can introduce additional third-party risk that is not always obvious at first. For example:

  • The merchant may rely entirely on the operator’s AML program
  • The financial institution may have limited visibility into transaction activity
  • Compliance accountability may be unclear or misunderstood

In some situations, merchants are unaware of the regulatory requirements tied to BTMs. Unscrupulous providers may place machines without fully explaining the responsibilities involved. That lack of transparency can expose both the merchant and the financial institution to risk.

Even when the merchant is not the operator, the presence of a BTM should influence how the relationship is risk-rated and monitored.

Customer due diligence and risk rating

Financial institutions should incorporate BTMs into their customer due diligence and risk assessment processes.

At onboarding and during periodic reviews, consider:

  • Does the customer own, operate, or host a BTM?
  • Who is responsible for regulatory compliance?
  • Is the operator registered with FinCEN?
  • Is the appropriate state licensing in place?

The presence of a BTM does not automatically make a customer high risk. However, it should prompt a closer evaluation of the customer’s overall risk profile and may warrant enhanced due diligence.

Ongoing monitoring is equally important. Changes in ownership, transaction volume, or business activity should trigger reassessment.

Red flags

In addition to understanding the structure of the relationship, financial institutions should be aware of transactional red flags associated with BTMs. Incorporating these into your cryptocurrency ATM monitoring processes can help identify potential issues early.

Examples of suspicious activity may include:

  • Repeated cash deposits followed by immediate cryptocurrency purchases
  • Customers structuring transactions to avoid identification thresholds
  • Multiple individuals using the same machine in a coordinated manner
  • Unusual transaction volumes inconsistent with the business type
  • Customer complaints indicating confusion or possible fraud

These patterns should be evaluated within the institution’s existing suspicious activity monitoring framework and escalated when appropriate.

Internal processes and training

Effective cryptocurrency ATM monitoring requires coordination across multiple teams. Frontline staff, lenders, and BSA professionals all play a role in identifying and managing risk.

Financial institutions should:

  • Train staff to recognize BTMs during site visits
  • Update procedures to require documentation and photos of machines
  • Enhance customer questionnaires to include cryptocurrency-related questions
  • Ensure BSA and AML teams understand how BTM activity fits into monitoring systems

A lack of awareness at the frontline level can lead to missed risk indicators. Ongoing training and clear communication help ensure that emerging risks are consistently identified and addressed.

Practical steps

To strengthen your approach, consider implementing the following:

  • Ask all business customers whether they have an ATM or a BTM
  • Identify who owns and operates the machine
  • Obtain FinCEN registration details and verify licensing where applicable
  • Maintain copies of BTM agreements, including AML compliance language
  • Incorporate BTM activity into your risk assessment and monitoring processes

If agreements do not clearly address compliance responsibilities, that may signal a need for further review.

Looking ahead

Cryptocurrency and alternative payment channels continue to evolve. As adoption increases, regulators are likely to maintain or expand their focus on these areas.

Financial institutions that take a proactive approach to cryptocurrency ATM monitoring will be better positioned to manage risk, support their customers, and meet regulatory expectations. This includes building scalable processes, leveraging technology where appropriate, and ensuring staff are equipped with the knowledge they need.

Understanding the difference between an ATM and a BTM is no longer a minor detail. It is a necessary step in maintaining a strong, risk-based compliance program in a rapidly changing financial landscape.

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FAQs

What is a BTM?

A BTM, or Bitcoin Teller Machine, is a kiosk that allows users to buy or sell cryptocurrency using cash, debit cards, or digital wallets. For banks and credit unions, BTM activity may require monitoring as part of AML transaction monitoring and financial crime compliance workflows.

What is the difference between an ATM and a BTM?

An ATM allows customers to access traditional banking services, while a BTM, or Bitcoin Teller Machine, allows users to buy or sell cryptocurrency. For banks and credit unions, understanding the difference helps BSA/AML teams identify crypto-related transaction activity that may require enhanced monitoring.

Why should financial institutions monitor cryptocurrency ATM activity?

Financial institutions should monitor cryptocurrency ATM activity because it can create elevated fraud, money laundering, and scam risk. AML transaction monitoring software can help banks and credit unions detect unusual cash withdrawals, rapid movement of funds, or customer behavior connected to crypto scams.

What red flags may indicate suspicious BTM-related activity?

Suspicious BTM-related activity may include repeated cash withdrawals, transactions inconsistent with a customer’s profile, elderly customers sending funds after coercion, or activity tied to known crypto scam patterns. Abrigo-related AML/CFT workflows can help financial institutions identify, investigate, and document these red flags more consistently.

How can banks and credit unions reduce risk from cryptocurrency ATM transactions?

Banks and credit unions can reduce cryptocurrency ATM risk by combining staff training, customer education, risk-based monitoring, and clear escalation procedures. Financial crime compliance software can support this process by centralizing alerts, customer data, investigation notes, and SAR decisioning.