We require the lenders to insure that the purpose of the loan is stated per our internal lending procedures.
As noted, the regulation does not require a statement of purpose on all loans or stipulate where the information should be recorded. However, if your own policy requires it on
all loans then a failure to obtain it on
any loan could/should be listed as a criticism in a BSA/AML examination.
"Personal" or "business" is not a statement of purpose. The description should be adequate to allow a reviewer to "chase proceeds" and compare the borrower's use of the funds to the stated purpose of the loan.