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#8153 - 12/21/01 03:42 PM OFAC and purchasing loans
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
Am I being too conservative to require that loans (mortgages) that we (a bank) purchase from outside banks or from a non-bank affiliate would have been screened against the SDN lists, etc.?

Have a nice holiday!

Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy

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General Discussion
#8154 - 12/21/01 04:06 PM Re: OFAC and purchasing loans

That's a good question, I know that the loans we sell to Freddie Mac, Fannie Mae, and Ginnie Mae do not have any requirements for us to check the SDN list before they buy the loans from us. I supposed that's something that could very well change in the near future.

opinions expressed are my own and not those of my employer

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#8155 - 12/21/01 04:47 PM Re: OFAC and purchasing loans
Rubaiyat Offline
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Joined: Jun 2001
Posts: 1,373
Lido Deck
Based on what our regulators are telling us I don't think you can be too conservative when it comes to OFAC. As a result of a recommendation at a recent meeting with our EIC, we are now screening any non-customer loan applicant(customers would have already been checked) against the SDN list prior to funding any loan. If it were me, I would also carry that over to purchased loans as well.

I don't know about you, but I think OFAC is beginning to look like a full time job!

--A bad day at sea is better than a good day at work.

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