Is your bank an ODFI?

Answered by:

Question:

We only process loan payments for our customers, where our customer can make loan payments using their account at another bank. Are we an ODFI or RDFI?

Answer:

Your bank is an ODFI! Even a low-risk origination program, such as loan repayments, makes the bank an ODFI and responsible for related audits and risk management initiatives.
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