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November 19
How to Conduct an Interrogation
Dana Turner

November 19
Blocking Internet Gambling -- Are You Ready?
John Burnett

November 20
Understanding Letters of Credit
Adam LaBoda

December 2
Auditing for the "Orphan" Compliance Regulations
Patricia Cashman

December 8
Robbery Suppression & Apprehension -- The SAFECATCH Strategy
Dana Turner

December 10
RESPA - Completing the New Good Faith Estimate
Mary Beth Guard and
Jack Holzknecht

December 16
RDC Risk Management and FFIEC Compliance: It is harder than you think!
Paul Carrubba and
Dan Fisher

December 18
RESPA - Completing the New HUD-1/1A
Mary Beth Guard and
Jack Holzknecht



Topic Options
#1273559 - 10/26/09 11:43 AM Loan operations internal controls
HuskerBanker Offline
Junior Member

Registered: 02/10/09
Posts: 30
Loc: Midwest
Our small bank monitors the new account report diligently. We also monitor employee accounts.

Given these controls, what are the risks with allowing a loan officer to post loan advances for his/her customers?

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#1274095 - 10/26/09 05:03 PM Re: Loan operations internal controls [Re: HuskerBanker]
goneyard Online
New Poster

Registered: 01/05/06
Posts: 19
Loc: Mid USA
Always risky, but if you have dual controls on the process, it might be acceptable.

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#1275348 - 10/27/09 03:34 PM Re: Loan operations internal controls [Re: goneyard]
HuskerBanker Offline
Junior Member

Registered: 02/10/09
Posts: 30
Loc: Midwest
Can anybody's loan officers do loan account maintenance?

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#1275388 - 10/27/09 03:56 PM Re: Loan operations internal controls [Re: HuskerBanker]
OnTheEdge Online
Diamond Poster

Registered: 04/25/02
Posts: 1233
Loc: Rural Southeast
Not here, nor at my previous bank.
_________________________
"If you don't think too good, don't think too much!" Ted Williams

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#1275555 - 10/27/09 06:28 PM Re: Loan operations internal controls [Re: HuskerBanker]
califgirl Offline
Diamond Poster

Registered: 03/04/02
Posts: 1217
Loc: California
Originally Posted By: HuskerBanker
Can anybody's loan officers do loan account maintenance?


I wouldn't let them anywhere near it.
_________________________
How beautiful it is to do nothing, and then rest afterward...
Spanish proverb

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#1275602 - 10/27/09 09:39 PM Re: Loan operations internal controls [Re: califgirl]
Just Jay Online
Compliance is my life

Registered: 10/26/06
Posts: 10135
Loc: Behind the cheddar curtain
Nope.
_________________________
Is this respa thing I keep hearing about something I should be concerned with?

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#1276983 - 10/29/09 01:05 PM Re: Loan operations internal controls [Re: Just Jay]
Ms Auditor Offline
100 Club

Registered: 10/11/01
Posts: 137
Loc: Upstate NY
Our loan officers do not have authority to perform account maintenance.

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#1278363 - 11/02/09 11:58 AM Re: Loan operations internal controls [Re: Ms Auditor]
Okie Banker Online
Diamond Poster

Registered: 01/14/03
Posts: 1200
Loc: Oklahoma
No way. But I've never worked at a small bank. That would make it more difficult. It would all depend on your controls and audits to make that work.
_________________________
If the facts to not conform to the theory they must be disposed of.

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#1278449 - 11/02/09 01:33 PM Re: Loan operations internal controls [Re: Okie Banker]
Passing storm Offline
100 Club

Registered: 08/02/05
Posts: 100
Loc: Here and Now
Not at our bank. Segregation of duties
_________________________
Don't believe everything you think

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#1278986 - 11/03/09 09:43 AM Re: Loan operations internal controls [Re: Passing storm]
HuskerBanker Offline
Junior Member

Registered: 02/10/09
Posts: 30
Loc: Midwest
In order for our loan officers to be able to do loan advances for customers they need to have full loan maintenance capabilities. We are small and our loan officers need to be able to do the advances.

Does anyone else use Fiserv and have that problem?

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#1279144 - 11/03/09 11:25 AM Re: Loan operations internal controls [Re: HuskerBanker]
stefrio Offline
New Poster

Registered: 05/02/06
Posts: 20
At a previous employer who used Fiserv, the loan officers gave their advances to an Operations person to process on a block. This offered a little control but keeps the maintenance out of Loan Officers hands.

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#1281141 - 11/04/09 05:49 PM Re: Loan operations internal controls [Re: stefrio]
Just Jay Online
Compliance is my life

Registered: 10/26/06
Posts: 10135
Loc: Behind the cheddar curtain
Do your loan officers put the loans online as well?
_________________________
Is this respa thing I keep hearing about something I should be concerned with?

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#1282356 - 11/06/09 10:05 AM Re: Loan operations internal controls [Re: Just Jay]
HuskerBanker Offline
Junior Member

Registered: 02/10/09
Posts: 30
Loc: Midwest
No, the loan assistants do this per our dual control procedures. But with the system limitations, the loan officers still could do it if they wanted to try and get away with something.

Do you feel the new loan report review (although loan has already been funded at this time) and employee account review (but who would really use their own name?) are sufficient compensating controls?

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#1283395 - 11/09/09 11:46 AM Re: Loan operations internal controls [Re: HuskerBanker]
Passing storm Offline
100 Club

Registered: 08/02/05
Posts: 100
Loc: Here and Now
If the new loan report provides the identification of who put the loans on line and it is being checked to ensure the loan officer is not performing that function. But the best controls would be to limit the loan officer's access capabilities.
_________________________
Don't believe everything you think

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