Introducing the Social Currency Podcast

Social Currency, powered by Sunrise Banks, is a podcast that introduces you to some of the most innovative changemakers in fintech and ESG (environmental, social and governance), and how they are dismantling barriers and reshaping their industries for a more inclusive, equitable and sustainable future.

Here we speak to those at the forefront of positive change through social entrepreneurship to unveil the stories behind the revolution that is propelling us toward a world where everyone has equitable access to opportunities.

Follow Social Currency on LinkedIn Off Site Link, Facebook Off Site Link and Instagram, and subscribe wherever you get your podcasts!

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Values Based Banking Guidelines

Sunrise Banks’ mission is to provide innovative banking for good. As a Treasury‐certified Community Development Financial Institution (CDFI), a member of the Global Alliance for Banking on Values, and a B Corp, Sunrise Banks strives to offer safe, affordable, and transparent products and services to our customers. As such, we also strive for clear and transparent communication with our partners and prospective partners.

These guidelines are meant to outline specific product terms and fees that Sunrise Banks has to ensure we are meeting our mission and that we are partnering with companies with similar values. All product terms and fees/pricing not listed here are still subject to review and approval by the bank. The compliance team considers the target market, product purpose, current regulatory guidance, and recent enforcement actions when reviewing all products and services for potential consumer harm. Sunrise provides additional guides for collateral, complaints, UDAAP, etc. which should not be considered to override or supersede any requirements noted in these guidelines.

Sunrise Banks Requirements

Loan Terms and Fees

• The following applies to all consumer loans, and to commercial loans as indicated.
• Loans must be affordable and based on the borrower’s ability to repay an obligation¹, not based on the assets of the borrower.
• Loans must not induce a borrower to refinance a loan repeatedly (“loan flipping” or “loan churning”);
• Loan terms must be clear and conspicuous, reflecting the true nature of the obligation or ancillary products.
• Military Annual Percentage Rates (MAPRs) as defined by 32 CFR 232 (Military Lending Act) may not exceed 36%. This requirement applies to both MLA covered and non‐covered borrowers.
• Small business loans may not exceed 36% APR as defined by 12 CFR 1026 (Regulation Z)².
• Fees must be accurately defined as finance charges when applicable. Loans that charge “back‐end” or non‐APR fees to circumvent to 36% MAPR maximum are not allowed.
• May not charge prepayment penalties. Consumers should be able to pay off debt without penalty.
• Loans may not allow for negative amortization.
• Loan servicing fees must be reasonable for the service being provided. Servicing fees designed to generate a profit rather than to recoup costs are not permitted (e.g. charging excessive fees for a customer to make a payment, or “pay to pay” fees)
• May not sell Sunrise‐originated charged‐off consumer or small business debt to debt buyers.

Deposit Account Fees

All deposit fee restrictions apply to both consumer and commercial accounts.

• Negative balance fees (fee charged when an account has had a negative balance for X days)
• Deposit item return/chargeback fees (fee charged when a customer deposits a check, and the check is returned by the paying bank).
• Decline fees (charged instantaneously when a transaction is declined).
• Transaction fees for point‐of‐sale (POS) transactions (PIN or signature based).
• Inactivity fees on savings accounts.
• Inactivity fees on DDA and GPR products prior to 12 months of inactivity.
• ATM balance inquiry fees unless charging only the cost of the inquiry and balance can be checked free of charge via IVR.
• Overdraft³ and NSF fees that exceed the amount of the item presented.
• Charging more than 6 overdraft fees in a rolling 12‐month period.
• NSF fees on re‐presented items.

While the bank does not currently have requirements regarding the dollar amount of allowable fees, these will be reviewed with all products for reasonableness as noted above.

¹ This does not mean all loans must consider ability to repay (e.g. credit builder loan), rather it applies when repayment is dependent on foreclosure or repossession of an asset. The ability to pay requirement may be waived if there is a community development purpose for doing so.
² While we understand that Regulation Z does not apply to small business loans, we must ensure compliance with this requirement to maintain our CDFI certification.
³Additional requirements and disclosures may apply to overdraft fees and services depending on the nature of the product.