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#2197385 - 11/05/18 10:40 PM Beneficial Ownership obtained at loan closing
parr04 Offline
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Joined: Aug 2004
Posts: 394
oklahoma
We currently require all Beneficial Ownership documentation to be obtained prior to processing any loan to a legal entity customer . The Chief Lending Officer is now requesting we relax this requirement and allow the Beneficial Ownership documentation be collected at loan closing.

I would like to know what other banks are doing. Do you require Beneficial Ownership documentation prior to processing or do you allow your officers to collect it at loan closing?

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#2197528 - 11/07/18 10:54 AM Re: Beneficial Ownership obtained at loan closing parr04
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
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It would be "compliant," but would have some practical problems; e.g. if you are going to obtain personal guarantees from the owners, how do you know who they are and incorporate their information into the underwriting process?
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#2197672 - 11/07/18 08:09 PM Re: Beneficial Ownership obtained at loan closing parr04
TryingtoComply Offline
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Joined: Apr 2013
Posts: 2,199
The West
The form is required before documents can be drawn at our shop. Exceptions must be approved by me or our Chief Risk Officer. We have had NO problems with our RMs complying with this requirement. Everyone has gotten used to it.
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