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#2096312 - 08/31/16 04:48 PM OFAC screening of loan applicants
jhoch Offline
Member
Joined: Nov 2014
Posts: 66
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?

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#2096313 - 08/31/16 04:49 PM Re: OFAC screening of loan applicants jhoch
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 77,568
Galveston, TX
Any potential land mines?

Going through a lot of time and expense for nothing - but then again if you never have a match - the loss would be zero.
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#2096327 - 08/31/16 05:18 PM Re: OFAC screening of loan applicants rlcarey
jhoch Offline
Member
Joined: Nov 2014
Posts: 66
Yes. I agree. I guess I'm looking to see if anyone who does the same thing ever had any regulators say anything about it.

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#2096330 - 08/31/16 05:23 PM Re: OFAC screening of loan applicants jhoch
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 77,568
Galveston, TX
There would be nothing to say.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2096779 - 09/02/16 02:52 PM Re: OFAC screening of loan applicants jhoch
fmissle Offline
Platinum Poster
Joined: Jul 2007
Posts: 959
Pac NW
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.

Have not had any comments on it.

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#2097017 - 09/06/16 05:49 PM Re: OFAC screening of loan applicants jhoch
M23 Offline
Junior Member
Joined: Oct 2009
Posts: 34
NC
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.

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