Being in small/intermediate bank, it became clear to me that we may not be monitoring loan modifications for beneficial ownership. With that said, there doesn't appear to be an easy way to track modifications in situations in which a new account number is not created and it went through underwriting/approval. There is no automation software in place and running reports requires someone with exception coding knowledge which we do not have.
Hypothetically, I might be able to pull a report that tracks changes in commitment amounts or term lengths but it will be difficult to find someone with that knowledge. Do any small/manual banks have suggestions on how to track loan modifications that would trigger beneficial ownership? Could I add a statement to the beneficial ownership form that would cover loan modifications/renewals that says the customer would inform the bank of any changes in such an area and be safe?
Any insight would be appreciated.