Consumer Loan Policy
This Consumer Loan Policy addresses consumer loan products, underwriting, and related lending operations of a bank, credit union, fintech company, or other type of financial institution. In general, the primary purpose of an organization’s consumer lending operations is to generate income while serving the credit needs of all creditworthy consumers within its geographic area by maintaining an effective loan policy and underwriting standards, in conjunction with sound loan administration by its officers and lending personnel, in order to achieve a healthy loan portfolio.
Table of Contents
- Purpose and Contents – Topic 1
- Policy Statement – Topic 2
- Definitions – Topic 3
- Risk Management – Topic 4
- Responsibility – Topic 5
- General Credit Underwriting Guidelines – Topic 6
- Account Management – Topic 7
- Unsecured Term Loans – Topic 8
- Revolving Lines of Credit – Topic 9
- Vehicle Loans – Topic 10
- Boat/RV/Trailer Loans – Topic 11
- Motorcycle and ATV Loans – Topic 12
- Overdraft Protection – Topic 13
- Savings/TCD Secured Loans – Topic 14
- Employee Consumer Loan Processing Procedures – Topic 15
- Payday, Vehicle Title, and High-Cost Installment Loans – Topic 16
- Marketplace Loan Program – Topic 17
- Student Loan Program – Topic 18
- Buy Now Pay Later Loans – Topic 19
- Program Reporting – Topic 20
- Collections – Topic 21
- Consumer Debt Sales – Topic 22
- Secured Loans Discharged in Chapter 7 Bankruptcy – Topic 23
- Non-Accrual Status – Topic 24
- Risk Rating Assignment – Topic 25
- Audit Policy – Topic 26
- Staff Training – Topic 27
- Retention of Documentation – Topic 28
Includes the following form templates:
- Consumer Loan Override Request – (1 page)
- Loan Presentation – Consumer – (1 page)
Recent updates to this product:
03/18/24 Update
Eliminate and/or modify references to the term “Troubled Debt Restructuring” (TDR) with a “Borrower Experiencing Financial Difficulty.”
12/18/23 Update
OCC Bulletin 2023-37 – Retail Lending: Risk Management of Buy Now, Pay Later Lending
05/15/23 Update
FDIC FIL-19-2023 – Supervisory Guidance on Charging Overdraft Fees for Authorize Positive, Settle Negative Transactions
OCC Bulletin 2023-12 – Overdraft Protection Programs: Risk Management Practices
09/01/22 Update
OCC Bulletin 2022-20 – Accounting: Bank Advisory Series Updated – Accounting Standards Update (ASU) 2022-02 – “Financial Instruments – Credit Losses (Topic 326): Troubled Debt Restructurings and Vintage Disclosures”
03/01/22 Update
CFPB Bulletin 2022-03 – Servicer Responsibilities in Public Service Loan Forgiveness Communications
This Consumer Loan Policy (approximately 188 pages) is available to purchase from BankPolicies.com in Microsoft® Word format.
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