HMDA reporting continues to be a common source of examination findings, especially when loan types and data requirements are misunderstood. Key areas to watch include: Commercial Loans - Many HMDA reportable loans at community banks are commercial purpose loans secured by dwellings. Several data fields must be reported as “NA” rather than left blank. Understanding which fields apply is critical. Documentation - Every one of the 110 HMDA data fields should be supported by cons

Third party relationships continue to receive increased scrutiny from regulators, particularly as banks rely more heavily on FinTech's, core providers, and outsourced compliance services. Examiners are looking beyond contracts to evaluate: Vendor due diligence and ongoing monitoring Risk tiering and supporting documentation for the risk tier chosen Board oversight of critical vendors Alignment between vendor risk and internal controls Are your vendors using AI and are you ask