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#1709738 - 06/13/12 03:41 PM Separation of Duties
Anonymous
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Can someone please advise on credit review specialists acting as credit underwriter while also having voting approval for OLC committee?

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#1709748 - 06/13/12 03:55 PM Re: Separation of Duties Anonymous
rlcarey Offline
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rlcarey
Joined: Jul 2001
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Galveston, TX
OLC Committee? And in what regulatory context are you referring?
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#1709776 - 06/13/12 04:24 PM Re: Separation of Duties Anonymous
John Burnett Offline
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John Burnett
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Cape Cod
Like an ATM machine, I think the OLC Committee is the Officers Loan Committee Committee.
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#1709816 - 06/13/12 04:47 PM Re: Separation of Duties Anonymous
Anonymous
Unregistered

Under Appraisal Guidance anyone with voting authority should be removed from the appraisal function. All loans over $1 million go to Officer Loan Committee for approval. Currently our CCO has voting authority on OLC. This person also oversees our appraisal orders, reviews, etc. While the decision is not theirs alone I believe this to be a conflict.

This also leads me to ask how other banks handle their credit analysts - Do they serve as a non-voting advisory member of loan committee or do they have have voting authority?

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#1710010 - 06/13/12 07:43 PM Re: Separation of Duties Anonymous
HRH Okie Banker Offline
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Joined: Jan 2003
Posts: 3,070
Oklahoma
Originally Posted By: Anonymous
Can someone please advise on credit review specialists acting as credit underwriter while also having voting approval for OLC committee?


Please explain do us what the duties are for a "credit review specialists". There is no violation, that I know of, for an underwriter to have voting approval. Many times you might find a loan committee voting member having to put together and underwrite a loan requrest because the analyst(s) might be too busy. The only violation, as mentioned above, is if your review specialist does appraisal review. In that case, it would be a violation of the Interagency Guidelines on Appraisals...
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#1710035 - 06/13/12 08:06 PM Re: Separation of Duties Anonymous
HRH Okie Banker Offline
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Joined: Jan 2003
Posts: 3,070
Oklahoma
Originally Posted By: Anonymous
This also leads me to ask how other banks handle their credit analysts - Do they serve as a non-voting advisory member of loan committee or do they have have voting authority?


Our head analyst is a non-voting (advisory) member. Other analysts may sit in committee when a loan they have prepared is being presented.
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