Due Diligence and Ongoing Monitoring

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Investors, Brokers, etc.

  • 1.  Investors, Brokers, etc.

    This message was posted by a user wishing to remain anonymous
    Posted 15 days ago
    This message was posted by a user wishing to remain anonymous

    For non-bank lenders, their investors, brokers, dealers, etc., do not consider themselves to be vendors of the lender.  How do you manage due diligence and annual updates when they will not complete vendor questionnaires, etc. ?  From public info only?  Or?

  • 2.  RE: Investors, Brokers, etc.

    Posted 13 days ago
    Good question.  Non-bank lenders seem to have this problem because secondary market investors, brokers, dealers, et al can all easily be replaced with one phone call.  I've had some success in the past using a very short due diligence questionnaire.  The long questionnaires take time to fill out and for the vendors we're discussing, time is money.  The other actions you may choose to take are to assure each vendor that doesn't feel they have to comply that two things may happen. (1) you may choose to use a different vendor, (2) depending upon your prudential regulator, you may be required to notify your prudential regulator & the SEC.

    Of course, you should always have a backup for each of these before you start communicating with them.