TOPIC: Adverse Action

Subordinations

Manager at a credit_union ($854MUSA)
As I am sure you are like us, we have been getting a ton of requests from other FIs for a subordination.  If you deny a subordination request (due to LTV) is it required to send out an Adverse Action Notice?  I didn't think that it was required but wondering how others handle this?

    Due Diligence - Lending Background Checks

    AVP at a bank ($1.5BUSA)
    Hello all - 

    Wondering if any of you run background checks, or enhanced Google searches of your lending applicants? If so, would any of you be willing to share your guidelines on what you consider a disqualifier? We attempted to start with the SBA SOPs but they weren't very helpful as there wasn't much detail outside of have you been convicted previously or arrested in the past 6 months. 

    Thank you,
    Angelina

      Closing open-end loans for MRB purpose

      Employee at a credit_union ($3.8BUSA)
      Hi all,

      We are curious what others are using for the “specific” denial reason on an adverse action notice when removing a credit limit on an open-end loan or credit card when marijuana-related activity is discovered on the personal accounts (savings, checking, etc.) and your policy is to close the entire relationship which includes the credit card and/or loan account.

      Thank you