Most Popular Operations Content
Relevancy of checks
12/15/2024
Are checks still relevant in today’s digital payment era?
Appraisal Bias and the risk to your fair lending program
12/15/2024
How can appraisal bias effect my fair lending program? We use a third-party
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?
The digital divide, redlining and fair lending programs.
12/08/2024
How can digital email cause my institution redlining issues?
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?”