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After Hours Change Orders

12/15/2024

We're exploring the idea of cash lockers - night drop meets ITM (similar to Amazon lockers at Whole Foods). The concept is for commercial clients to be able to pick up change orders after hours. Have you heard of this anywhere or know of any best practices?

HMDA/Section 1071 Question

12/08/2024

I have a question about a SBDC exclusion. I know that the exclusions reference that HMDA reportable transactions are excluded. We are a non HMDA bank so what we initially thought based on the prior SBDC trainings I have been to and the research that we have done is that we would exclude transactions that would be HMDA reportable if we were a HMDA reportable bank. However, I recently went to a Forvis compliance conference and what I heard there caused some confusion for me in regards to that. We are a non HMDA bank due to us not having a branch in an MSA and not because of our loan volume. So their interpretation was that HMDA transactions would not be excluded for us since we don’t have a bank in an MSA and since our loan volume wouldn’t exclude us from HMDA if we were in an MSA. I can see following the citations how they derived to that answer but this is the first time I had heard it interpreted that way. Can you give any guidance or clarification on this?”

Reg E and mobile payments

12/01/2024

Our customer received a call telling them their CashApp account was compromised, and they needed to verify the password. After they did this there were several authorized CashApp transactions. Can we tell the customer they have to resolve the issue with CashApp?

Responsibility for payment of counterfeit check

12/01/2024

If we have a business customer that notified us that a check cashed against their account was "altered" and that check was determined to be a counterfeit, but the signature on the check reasonably matches the signature of the authorized signer (almost exactly), would we still be liable to credit our customer for the counterfeited check?

Business debit card disputes

11/24/2024

Since Reg E does not apply to businesses, do we have to investigate a fraudulent business debit card transaction?

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Most Popular Operations Content

After Hours Change Orders

12/15/2024

We're exploring the idea of cash lockers - night drop meets ITM (similar to Amazon lockers at Whole Foods). The concept is for commercial clients to be able to pick up change orders after hours. Have you heard of this anywhere or know of any best practices?

HMDA/Section 1071 Question

12/08/2024

I have a question about a SBDC exclusion. I know that the exclusions reference that HMDA reportable transactions are excluded. We are a non HMDA bank so what we initially thought based on the prior SBDC trainings I have been to and the research that we have done is that we would exclude transactions that would be HMDA reportable if we were a HMDA reportable bank. However, I recently went to a Forvis compliance conference and what I heard there caused some confusion for me in regards to that. We are a non HMDA bank due to us not having a branch in an MSA and not because of our loan volume. So their interpretation was that HMDA transactions would not be excluded for us since we don’t have a bank in an MSA and since our loan volume wouldn’t exclude us from HMDA if we were in an MSA. I can see following the citations how they derived to that answer but this is the first time I had heard it interpreted that way. Can you give any guidance or clarification on this?”

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