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#816950 - 09/18/07 01:01 PM
BSA Loan Purpose
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Gold Star
Joined: Jul 2007
Posts: 436
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I believe the BSA issue falls under 103.33(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; (emphasis added by me) _________________________ From this thread in lending I have a question. Do I need to nit pick about loan purpose under $10,000. I have sort of been doing that and surely I need to pick my battles. (How can I learn how to transfer thread lines like the rest of you? Specifically I see them copied in a box with blue highlights. And mine doesn't show the author. Is there someplace on the site that has these types of instructions?)
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#816956 - 09/18/07 01:12 PM
Re: BSA Loan Purpose
trail hiker
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Diamond Poster
Joined: Oct 2001
Posts: 1,570
Wisteria Lane..
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Do I need to nit pick about loan purpose under $10,000. You are OK for BSA purposes on loans under $10,000, but when the borrower doesn't state the purpose of the loan how do you know whether it is HMDA reportable or not?
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And where is Superman when I need him?
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#816958 - 09/18/07 01:15 PM
Re: BSA Loan Purpose
LoisLane
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10K Club
Joined: Sep 2002
Posts: 13,965
TN
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Sorry, but I nit pick. I think the Bank should have a specific purpose on each and every loan.
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My Opinions Only
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#816961 - 09/18/07 01:17 PM
Re: BSA Loan Purpose
LoisLane
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Gold Star
Joined: Jul 2007
Posts: 436
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I've been working on that issue as well. But now I know I don't have to insist that under $10,000 is a BSA issue as well. But BSA might have a greater impact when telling people why something is necessary. Thanks, Lois.
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#816993 - 09/18/07 02:15 PM
Re: BSA Loan Purpose
Skittles
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Diamond Poster
Joined: Nov 2005
Posts: 2,409
SW GA
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I agree. The more employees consistently follow procedures, the fewer exceptions there should be. Why try to remember a monetary cut-off figure? Does anyone accept "personal expenses" and/or "equity loan" as the purpose for a loan?
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Semiretired. Working parttime at Historic Westville as a tour guide.
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#817000 - 09/18/07 02:20 PM
Re: BSA Loan Purpose
Bagweaver
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10K Club
Joined: Sep 2002
Posts: 13,965
TN
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The only loan where we are accepting vague responses are for HELOCs. This can be understandable in this instances. Although we still have lenders who don't understand the concept of obtaining a specific purpose.
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My Opinions Only
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#818501 - 09/19/07 07:55 PM
Re: BSA Loan Purpose
Skittles
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100 Club
Joined: Jan 2006
Posts: 200
USA
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If a borrower refinances an in-house car loan for $20,000 and gets $5,000 cash out, do we need a loan purpose?
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#818896 - 09/20/07 12:49 PM
Re: BSA Loan Purpose
Skittles
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Power Poster
Joined: Oct 2003
Posts: 2,548
Southeast
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Sorry, but I nit pick. I think the Bank should have a specific purpose on each and every loan. I agree with Duchess Skittles. See bottom of page 1 and top of page 2. http://www.occ.treas.gov/FTP/EAs/ea2007-011.pdf
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Politicians are like diapers. They need to be changed often and for the same reason.
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#820541 - 09/21/07 05:13 PM
Re: BSA Loan Purpose
Retread
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Diamond Poster
Joined: May 2007
Posts: 1,185
Miami
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I agree that the bank should have some knowledge of the loan purpose...but how far do you go? If the customer stated that the loan was to buy widgets, do you ask for an invoice or relevant evidnece showing that he in fact purchased widgets? Also, how many institutions require that a loan customers also have a deposit realtionship ay your bank.
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#820978 - 09/21/07 08:22 PM
Re: BSA Loan Purpose
Little Miss BSA
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Power Poster
Joined: Oct 2001
Posts: 5,564
Clintonville, WI, USA
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I nit pick when the purpose given is stated as "personal" or "personal expenses". That, in my opinion, is not enough of a description.
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#866299 - 12/04/07 11:38 PM
Re: BSA Loan Purpose
ksm
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Diamond Poster
Joined: Mar 2007
Posts: 2,108
gone fishin'
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Do you need to have a purpose for Line of Credits over $10k?
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My opinions are my own, and not that of my employer.
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#866342 - 12/05/07 03:50 AM
Re: BSA Loan Purpose
WonderWoman
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10K Club
Joined: Oct 2000
Posts: 27,752
On the Net
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31 CFR §103.33 Records to be made and retained by financial institutions.
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;
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AndyZ CRCM My opinions are not necessarily my employers. R+R-R=R+R Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell
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#1803894 - 04/11/13 06:40 PM
Chapter X Record Retention requirement for credit
trail hiker
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100 Club
Joined: Jan 2011
Posts: 170
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I was doing some BSA record retention research today and looked at Chapter X's § 1020.410 (Records to be made and retained by banks) and didn't see the recordkeeping requirement for extensions of credit over $10k not secured by real property. Any idea where that requirement is now codified?
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#1803900 - 04/11/13 06:43 PM
Re: Chapter X Record Retention requirement for credit
trail hiker
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10K Club
Joined: Jul 2001
Posts: 83,371
Galveston, TX
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§ 1010.410 Records to be made and retained by financial institutions.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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