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#1421314 - 07/29/10 01:02 PM Wire Transfer Origination for Loan Draw
RBanker Offline
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RBanker
Joined: Jul 2003
Posts: 2,675
Austin Texas
Wondering how other 1 office, small banks handle the following:
Authority levels and approvals for wire transfer loan fundings -
Currently we allow the loan office on the account to sign the wire transfer request as the originator, then a second officer has to approve the wire request and enter it in the wire system, then a third officer has to verify and approve the wire in the wire system.
Is this what most of you are doing? And how do you determine youre origination/approval limits?
We're thinking they should be the same as the lenders lending authority, with incremental limits to allow two lenders to originate a draw over a single officer's limits.
We haven't been cited in any of our audits or exams, we're just trying to write down our process/procedures and make sure we're doing this right.
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Operations Compliance
#1421438 - 07/29/10 02:48 PM Re: Wire Transfer Origination for Loan Draw RBanker
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,637
Galveston, TX
If you don't have a wire authorization agreement or wire order signed by the customer, all the approval processes in the world are not going to save you. Lenders should not have "authority" to initiate wires, that authority belongs to the customer. It's a great set up for lending fraud.
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#1421559 - 07/29/10 04:55 PM Re: Wire Transfer Origination for Loan Draw rlcarey
Banker Offline
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Joined: Oct 2007
Posts: 128
Southeastern US
We require a customer signature or either an email following by a verifying phone call to the customer. Then, the employee who takes the wire information must verify and sign the form. That employee must then get a member of management to sign the form with approval. Another employee then enters the wire into the system and a second employee must authorize the transaction to be sent. Yet, another employee balances the account next day to ensure all entries were made properly. This is something that we have had to change several times to keep auditors and examiners happy. Segregation of duties gets very tricky at a small bank. Hope this helps.

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#1421901 - 07/29/10 11:48 PM Re: Wire Transfer Origination for Loan Draw Banker
RBanker Offline
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RBanker
Joined: Jul 2003
Posts: 2,675
Austin Texas
When a draw is requested it requires a lender to approve the draw to determine that an inspection has been done, etc -
As stated in line two of my question, I'm asking about wires for loan fundings, when we wire the money to the customer's bank or to the title company for a closing. You're saying that the customer closes at the title company and is then going to have to come to the bank to sign the wire request?
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My comments are absolutely no reflection of, nor influenced by, my employer - take them at your own risk.

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#1421903 - 07/30/10 12:14 AM Re: Wire Transfer Origination for Loan Draw RBanker
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,281
That is not necessary for a loan draw, especially a new loan. Most banks discuss disbursement with the borrower ahead of time and have everything set up - payments to title companies, the borrower's accounts elsewhere, other third parties, etc.

You might provide a document at closing that spells out what is being wired to whom.
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