Looking for comments on changing OFAC screening from at the time a loan application is entered to pre-booking/funding. Currently we screen at both steps - during the application phase and then shortly before booking. We are a low risk (only US customers and low risk product among other attributes) business and have never had a true match (knock on wood) so we are looking to change the process to only screen pre-booking. Any potential land mines?
We generally pull earlier in the process, during other preliminary workflow steps (credit, flood, ordering title pre-lim) but there have been times when it's pulled as docs are being created.
I was at a low-risk institution that pulled OFAC with the bureau...until we booked a loan that had a client added to the list between application and booking. After that, we pulled at application and again prior to funding.