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#1697432 - 05/09/12 03:19 PM Commercial Loan Compliance Checklist
Anonymous
Unregistered

Management is asking for a Commercial Loan Compliance Checklist:

I feel that the following is needed:

- Application
- Flood Search Checks and Policy if Necessary
- HMDA Data Sheet if Residential Property as Collateral
- OFAC Searches of Principals, etc.

Is there any Compliance Related information that I have missed?

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#1697450 - 05/09/12 03:29 PM Re: Commercial Loan Compliance Checklist Anonymous
Skittles Online
10K Club
Skittles
Joined: Sep 2002
Posts: 13,965
TN
Appraisal(?)
_________________________
My Opinions Only

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#1697455 - 05/09/12 03:34 PM Re: Commercial Loan Compliance Checklist Anonymous
Anonymous
Unregistered

Thanks! Lol..I have it just didn't put on the list above!

Anything else?

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#1697688 - 05/09/12 06:29 PM Re: Commercial Loan Compliance Checklist Anonymous
Kevin_bank Offline
Junior Member
Joined: Feb 2011
Posts: 42
MO
An appraisal may not always apply depending on the loan. You may be considering an operating line of credit for example.

Also, I am not aware that there is a regulatory requirement to have an application with a commercial loan. My understanding of Reg B is that a lender should capture the intent of borrowers but it does not require an application.

Having said this, it is my strong preference to simply use an application as standard practice for documenting the intentions of businesses and people to apply for a credit. I mention this because you may come to a discussion of what is required by the regulation vs. what is a really good idea. My best advice is become very familiar with Reg B and FCRA.

You may also want to get a list together for items such as entity documents (article's of organization, etc.)

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#1697900 - 05/10/12 12:44 AM Re: Commercial Loan Compliance Checklist Anonymous
Sisyphus Offline
100 Club
Sisyphus
Joined: Jun 2008
Posts: 222
CIP

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#1697901 - 05/10/12 01:14 AM Re: Commercial Loan Compliance Checklist Anonymous
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Adding on:
Reg U
UCC
Reg E (auto deduct for loan payments must be revocable, even for commercial loans if borrower is an individual)
Reg O
Reg W (affiliate transactions)
Reg BB (CRA)
Reg GG

If the bank does not use an actual application form (as the loans get larger that becomes less common) the loan write up serves to satisfy the "application" requirement. It has to be put in writing, but not necessarily by the borrower.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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