So I have in the past received guidance from examiners that the bank should "manage" their pipeline of active loans by having the loan officer contact the borrower at least every 30 days. Yes there is no specific regulation that requires this (after meeting ECOA notification requirements). However, they usually bring it up as an internal control issue to avoid a number of issues from fair lending to making sure your HMDA filing is correct.
I have had this conversation with multiple examiners while being as several institutions and we have always implemented the practice (I think itís a good practice just from a business perspective) with little or no objection. I recently changed banks and was working through a project to standardize processes. As a part of the project I indicated we should implement such a procedure. Initially no one objected, but now that the process is in place Iím getting push back from the ďhigh producersĒ who donít believe they should have to have contact with the borrower on a TBD file because it is just too much work.
Anyway Iím looking to get feedback and opinions on the practice and see what others are doing.
Thanks, in advance for your feedback and help.
Where I go there I am.