July 18, 2025

Vol. XLII, No. 6

Collateral Inspections: Use of Autonomous or Semi-Autonomous Technology

I. Introduction
The Nebraska Department of Banking & Finance ("Department") has recently issued Statement of Policy #20 (SOP) regarding the use of autonomous or semi-autonomous technology employed to conduct inspections of collateral taken to secure loans made by financial institutions chartered by the Department. The purpose of the SOP is to acknowledge that inspections may rely upon technology provided the bank has policies addressing the related laws, liability and technology assisted considerations.

In utilizing emerging technologies to supplement or supplant traditional inspection or appraisal methods for the evaluation of physical collateral, banks must ensure that, regardless of the technologies utilized, all inspections and appraisals are being conducted reasonably appropriately, and in a safe and sound manner.

II. Collateral Inspections
The Department expects all banks that utilize autonomous or semi-autonomous technology, such as drones or self-driving vehicles, to conduct such inspections to take steps to appropriately consider items such as liability, compliance with federal, state, and local laws, and any applicable privacy protections that may subject the bank to the risk of civil action or loss. This expectation is applicable to all such inspections regardless of whether conducted by bank employees, agents, and contractors, through a third-party vendor, or any combination thereof. Banks may address such considerations by the creation and implementation of policies and procedures, adequate insurance coverages, or through other liability or indemnity agreeements.

III. Sample Checklist
​The Department has developed the sample checklist linked below that captures the information necessary to demonstrate to Department examiners that inspections aided by autonomous and semi-autonomous technology are being done in a reasonable manner. While the sample form is included as an indexed document to this Statement of Policy, it is not required to be used, and other forms containing substantially similar information or items of review are also permissible. The form is in addition to the inspection and appraisal reports required by 45 NAC 14.
Sample Checklist

Full-Text PDF

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The foregoing Compliance Update is for informational purposes only and does not constitute legal advice. As a reminder, the NBA general counsel is the attorney for the Nebraska Bankers Association, not its member banks. The general counsel is available to assist members with finding resources to help answer their questions. However, for specific legal advice about specific situations, members must consult and retain their own attorney.