Sec. 103.33 says: Each financial institution shall retain either the original or a microfilm or other copy or reproduction of each of the following:
(a) A record of each extension of credit in an amount in excess of $10,000, except an extension of credit secured by an interest in real property, which record shall contain the name and address of the person to whom the extension of credit is made, the amount thereof, the nature or purpose thereof, and the date thereof;
Are the loan docs themselves good enough to satisfy the requirement?
I just reviewed a loan that a lender made for $12,500, on which they listed the purpose was listed as "personal". My argument is that under BSA we should be listing a more specific purpose. In this case it was debt consolidation.
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Opinions expressed here are mine, not necessarily my employers. This is not legal advice.