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?

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.

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.

There would be nothing to say.

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.

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.