Pre-Exam
The pre-exam planning and scoping process should include the following, as applicable:
- Review prior exam and supervision contact reports, and FPRs to identify any prior commercial lending concerns
- Prepare and provide the EIC with the commercial lending request package to include:
- Commercial Lending Items Request List
- Request for commercial loan portfolio data download, and
- Any applicable exam questionnaires, etc.
The Commercial Lending Items Request List will be available in the Job Aid Repository. Exam staff should customize the request list for each exam based on the size and complexity of a credit union’s commercial lending program. A review leader should provide the items needed request package to the EIC as early as possible, taking into consideration that the credit union should receive the Items Needed list no less than four weeks in advance of the actual start date of the exam.
- The EIC should provide the requested items to a review leader, if one has been designated, upon receipt of the items (preferably at least two weeks before arriving at the credit union or the start date of the review)
- Establish the scope of review for the commercial lending area and assign specific scope steps to team members
- Obtain the electronic commercial loan data download or, at a minimum, the share and loan download
- Select the loan review sample, assign individual loans to team members, and send the list of individual loans selected for review (loan review list) to the EIC to share with the credit union
The EIC should provide the loan review list to the credit union no sooner than one week before the team arrives at the credit union or the commercial lending review start date.
- Verify that the review team will have access to all commercial loan files and that requested review documents will be available upon arrival at the credit union
- Determine if loan files are maintained in electronic format or at another offsite location and ensure files are delivered to the location designated for the loan review, if maintained in hard copy
- Verify that the review team will have access to all equipment necessary for the review (computer terminals, passwords to access computer terminals or secured electronic portals, databases, etc.)
- Verify all pre-exam items requested have been provided by the credit union before the first day of the review, when possible
The commercial lending request package is provided to help the review team efficiently and effectively complete a commercial loan review. These documents are sent to credit union management to request that they provide the EIC and/or the commercial lending review leader as much information as possible before the review team arrives on site at the credit union (or start date). Examiners must always conduct the transfer of sensitive or confidential information in accordance with 13500.09,
Last updated on October 14, 2021