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#2273070 - 07/19/22 08:14 PM Beneficial Ownership requirements - Loan Renewal
Jennifer Offline
100 Club
Jennifer
Joined: Dec 2014
Posts: 185
The loan closed prior to beneficial ownership requirements (2017) and renews without underwriting and/or approval.

Does beneficial ownership information have to be collected?

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BSA/AML/CIP/OFAC Forum
#2273073 - 07/19/22 08:32 PM Re: Beneficial Ownership requirements - Loan Renewal Jennifer
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 82,507
Galveston, TX
Sorry - but how in the world can you renew a commercial loan that is over 4 years old without underwriting or approval? It must be a very very small loan.
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#2273321 - 07/25/22 12:20 PM Re: Beneficial Ownership requirements - Loan Renewal Jennifer
praBSA Offline
Gold Star
Joined: Aug 2018
Posts: 348
I would argue it's still exempt. Not a new account, not going to underwriting approval.

I'm not shocked a loan team does this. We run into BO problems with renewals that do go to underwriting/approval but get back dated like 6 months to maturity. It's a mess. Constant struggle getting explanations added to my exception reporting.

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