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#1971695 - 10/23/14 11:12 PM Business Purpose for Cash Secured LOC
StellaC Offline
Junior Member
StellaC
Joined: Dec 2009
Posts: 43
El Monte
When making a cash-secured LOC to an individual borrower, how to determine there is a business purpose established?

Is business purpose established when underwriters put down the purpose of line is for borrower's business? or we need more documentation to prove the borrower does have a business? or we need to go even further to prove the loan proceed goes to the business?

Please kindly let me know your thoughts. Thanks

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CRA
#1971698 - 10/23/14 11:15 PM Re: Business Purpose for Cash Secured LOC StellaC
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
This should be very obvious from commercial loan underwriting where the nature of the customer's business should be discussed, the purpose of the loan, source of repayment, etc. If this is not documented, the bank has a safety and soundness issue rather than a CRA issue. If it is a very small loan for business purpose, underwritten on the individual's credit, there still need to be standards for determining the business purpose. Visit with the lending area to determine the credit policy.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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