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#2222904 - 10/02/19 08:30 PM CBO for Loan with Increase at Renewal
TryingtoComply Online
Diamond Poster
Joined: Apr 2013
Posts: 2,199
The West
What is everyone doing with respect to loan renewals with an increase? Are you obtaining a new CBO or relying on an existing CBO that was obtained after 5/11/18?
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BSA/AML/CIP/OFAC Forum
#2222922 - 10/03/19 12:52 PM Re: CBO for Loan with Increase at Renewal TryingtoComply
#Just Jay Offline
10K Club
#Just Jay
Joined: Oct 2006
Posts: 14,390
Cheeseheadland
We obtain an updated certificate with any applicable renewal or modification. We see it as one more signature in a mess of others and essentially a non-event for our borrower.
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#2222924 - 10/03/19 01:49 PM Re: CBO for Loan with Increase at Renewal TryingtoComply
ColoradoAML Offline
Gold Star
Joined: Mar 2018
Posts: 338
We collect a new certification any time a loan modification or renewal requires underwriting. To the best of my knowledge, any increase at our institution requires the loan to be underwritten.

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#2223000 - 10/03/19 09:10 PM Re: CBO for Loan with Increase at Renewal TryingtoComply
TryingtoComply Online
Diamond Poster
Joined: Apr 2013
Posts: 2,199
The West
Thanks to both of you!
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