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#1371502 - 04/08/10 08:09 PM Adverse Action Denial Reason for an OFAC Hit
Anonymous
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We have a loan that meets our underwriting standards, however when we pulled credit it came back with an OFAC hit. Does anyone have any suggestions for the denial reason other than "other"?

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#1371563 - 04/08/10 08:51 PM Re: Adverse Action Denial Reason for an OFAC Hit Anonymous
Doug Hendrickson Offline
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Doug Hendrickson
Joined: Oct 2009
Posts: 3,927
First of all, have you determine that this is a true hit and not a 'false positive' (i.e., have you looked at the full information about the OFAC person/entity and compared that information against the person applying for the loan). For instance, the birth date.

I ask this only because some OFAC-checkers may not compare all of that information.
_________________________
I hear and I forget. I see and I remember. I do and I understand.--Confucius

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#1371571 - 04/08/10 08:58 PM Re: Adverse Action Denial Reason for an OFAC Hit Doug Hendrickson
Anonymous
Unregistered

Doug,
Yes we have determined that this is a true hit and not a false positive. We are trying to be very sensitive to using "other". This is the first one that we've come across as a true hit, so we want to tread lightly and do it correct the first time. smile

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#1371587 - 04/08/10 09:21 PM Re: Adverse Action Denial Reason for an OFAC Hit Anonymous
Doug Hendrickson Offline
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Doug Hendrickson
Joined: Oct 2009
Posts: 3,927
Luckily we have not encountered this situation.

However, I would advise our loan staff to check the 'other:' box under the 'other' category and then give the reason that an OFAC hit was returned by the credit reporting agency (if that's who the notice came from), including the fact that we ruled out a 'false positive'.
_________________________
I hear and I forget. I see and I remember. I do and I understand.--Confucius

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