Our latest S&S FDIC Exam report contains a list of documentation exceptions on some loan files. It lists things like Tax Returns, Insurance Expiration, Personal Financial Statements, etc.

This is outside of Regulatory Compliance & Audit (my normal function), but I’ve been asked by management to incorporate a documentation review into future loan audits. Now, I know what to look for as far as disclosures and other ‘compliance stuff’, but I’m at a loss as to what other documents to support the credit should be in the file.

I looked at the FDIC Exam manuals and have been unable to find a master list of what they look for on loans for S&S. Does such a list exist? Or would anyone be willing to share a matrix or listing of “this type of loan required this type of documentation”? Any tips or pointers would be greatly appreciated.

Follow your loan policy for your banks requirements and develope your list from that.

I would follow loan policy, but also talk to your loan review folks to see what they recommend as minimum loan documentation.

The "list" really is individual to every bank, depending on their loan policy or loan procedures.

I'd first start with reading your Loan Policy and determine if there are requirements set forth for each loan type. If you utilize any exception tracking software you might see if there are parameters set up in the system for loan types and document tracking per type that might help or get you started.

You might have to engage your lending management and lenders in the production of this list.

You are not just looking for financials and tax returns and insurance but you should be tracking Loan Agreement requirements and covenants - Minimum net worth, Debt Service Requirements, Borrowing Base Reports, Accounts Agings, Inventory Reports, Lease expiration dates, Inspections. Are you tracking expirations of UCC/EFS, the payment of life insurance premiums, expirations of ag-related Direct Notifications, Rent Rolls - just to name a few other examples.