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Getting Clean Loan Files
by Lois Kohn

To teach lenders how to produce "clean" loan files that have all the necessary documentation and no compliance violations, Lois Kohn tells us about the following technique for training.

For one loan training class, I wore an apron. In the front of the room where I stood, I had a clothes-line and a laundry basket. Inside the laundry basket were very large cut-outs of clothing (made out of poster-paper) with a word or two printed on each. As I discussed the regulatory requirements, I reached into the laundry basket, pulled out an item of "clothing" and hung it on the clothes-line with clothes-pins. (Yes, they still sell clothes-pins!)

I can't remember all the items, but here are a few:
  • On a "shirt" the words "Race & Sex" to remind them of the importance of gathering this for HMDA-reportable loans.

  • On a "pair of blue-jeans" the word "document" for the importance of documenting why you made the decision to approve or deny the loan, and how important this was for "marginal" approvals and denials.

  • On a pair of "boxer shorts" the words "Flood Insurance" to remind them that the flood certification couldn't be waived and why it had to be done even though the lender was sure the property wasn't in a flood zone.


I can't remember the other items I used, but I didn't have more than six pieces of clothing hanging on the line. At the end of the program, I pointed to each item hanging on the clothes line to review each of these really important areas.

If you create an entire outfit with one important point for each piece of clothing, it will make it easy to remember.

Lois Kohn
Lois Kohn has a Bachelor of Science in Business Administration from Samford University and is a Graduate of the ABA National Compliance School. She has 30 years in the banking industry, 20 as Compliance Officer for Colonial Bank (Birmingham, Alabama). Lois has conducted frequent banking seminars for bank employees and others, and was named Outstanding Instructor for the Birmingham A.I.B. Chapter (1998). In June, 2000, she moved to Dallas, Texas where she is currently Corporate Compliance Specialist with Colonial Bank.

First published on BankersOnline.com 8/27/01





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