Loan Origination Checklist Template

Assigned to the loan officer. The borrower type, jurisdiction and revenue answers recorded here decide which later phases and tasks appear.

• Log the application, the product and the date received — then the date it became complete, which starts the Reg B notice clock
• Record the borrower type and jurisdiction — Consumer or Commercial, US or UK; name the underwriter and the credit approver at the same time
• Record a US business applicant’s gross revenue band — $1 million or less, or more, in its last fiscal year; it sets the adverse action rules in Phase 4
• Check the file against the product’s document list — where the applicant can supply what is missing, send a notice of incompleteness within 30 days
• Verify the identity of borrowers, guarantors and beneficial owners — US banks under their CIP and beneficial ownership rule; UK firms under the MLRs 2017
• Screen every party against the sanctions lists you apply — and disposition any potential match before underwriting starts
• Collect Section 1071 small business data where it applies — covered US lenders from 1 January 2028; keep the answers from decision-makers under your documented firewall procedure, or give the required notice

Assigned to the underwriter, who must not be the loan officer who sourced the deal.

• Pull credit reports with a permissible purpose — for consumer applicants and for individual guarantors of a business loan
• Verify income or spread the financials — payslips and bank statements for a consumer; accounts and tax returns for a business
• Assess repayment capacity — affordability and debt-to-income for a consumer (UK lenders follow CONC 5.2A); debt service coverage and leverage for a business
• Value the collateral — check any valuation or appraisal against policy and record the loan-to-value
• Assess guarantees without requiring a spouse to sign where the applicant qualifies alone — Reg B 1002.7(d)
• Risk-grade and price the loan — record the grade, the pricing basis and every policy exception
• Write the credit memo — recommendation, structure, covenants, conditions and exceptions

The approval task is assigned to a named approver whose delegated limit covers the total exposure. The checklist halts until it is answered.

• Calculate total exposure to the borrower and connected parties — against lending and concentration limits
• Check for insider or related-party lending — US banks need prior board approval above the Regulation O threshold, with the insider abstaining
• Credit approval by the authorised approver — Approved or Not approved; exposures above the approver’s limit go to credit committee
• Record the decision — Approved, Approved on different terms (counteroffer), Declined, or Withdrawn or closed as incomplete
• Issue the commitment letter or offer — with the conditions of approval and an expiry date

Shown only when the decision is Declined, a counteroffer, or an application closed as incomplete. The due date is set from the Phase 1 dates.

• Calculate the notice deadline — 30 days after a completed application or after adverse action on an incomplete one; 90 days after an unaccepted counteroffer
• State the specific principal reasons — the actual reasons for the decision, not “did not meet our criteria”
• Add the FCRA disclosures where a consumer report was used — the credit score and key factors, the agency’s contact details and the right to a free report within 60 days
• Apply the business credit rules — revenue $1 million or less: 30-day timing, oral or written; over $1 million: notice within a reasonable time and written reasons if asked within 60 days
• UK: say when a consumer decline relied on credit reference agency data and name the agency — CCA s.157(A1); designated banks also offer declined SMEs a finance platform referral
• Send the notice and attach a copy — Reg B keeps records 25 months for consumer credit and 12 months for most business credit

Shown only when the borrower type is Consumer. The jurisdiction answer shows the US or the UK tasks.

• US: check covered borrower status under the Military Lending Act — before consummation; a covered borrower’s loan must stay within the 36% MAPR cap and carry the MLA disclosures
• US closed-end: deliver the Truth in Lending disclosures before consummation — APR, finance charge, amount financed and payment schedule
• US open-end: give the account-opening disclosures before the first transaction
• US: send the risk-based pricing notice where the terms were set using a consumer report — Regulation V, unless an exception applies
• UK: give the pre-contract credit information and adequate explanations before the agreement is made — CONC 4.2
• UK: record the 14-day right of withdrawal start date — CCA s.66A, for most unsecured agreements

Shown only when the borrower type is Commercial. Owned by loan documentation or legal, with the loan officer chasing the borrower.

• Prepare the facility and security documents from the approved terms — any change to pricing, covenants or security goes back to the approver
• Collect the conditions precedent — constitutional documents, board resolutions, signatory evidence, insurance and legal opinions
• Take the guarantees and any intercreditor agreements the approval requires
• Perfect the security — US: file the UCC-1 and any real estate mortgage; UK: register the charge at Companies House within 21 days (s.859A)
• Approve any condition precedent waiver — a waiver is a credit decision, so the approver signs it, not the loan officer

Runs on every approved loan. Funding needs a second person, and QC is done by someone outside the deal team.

• Pre-closing check — conditions met, documents match the approval, nothing material changed since the decision
• Execute the loan documents — confirm the signatories are authorised and every required party has signed
• Fund the loan after a second person checks the payee and disbursement instructions — confirm changed bank details by phone to a known contact
• Book the loan — rate, payment schedule, collateral, covenants, maturity and the first annual review date
• Diary the follow-ups — covenant tests, insurance renewals, UCC continuation before the five-year lapse
• Post-closing QC on the file — documents, disclosures, notice timing and approval authority, with exceptions logged for MI
• Close the file and set its retention date — under Reg B and your retention policy