Loan boarding runs the workflow framework against the transfer cycle from the origination framework to the servicing framework. Identity verification at loan boarding runs the lender’s know-your-customer framework, the entity-authority framework, and the regulatory-compliance framework against each new loan on the servicing platform. The framework runs against five verification cycles — the Customer Identification Program framework, the beneficial-ownership framework, the OFAC sanctions-screening framework, the taxpayer-identification-number framework, and the entity-authority-documentation framework. This article walks the identity-verification framework against the loan-boarding cycle for private lenders.

The Customer Identification Program framework

The Customer Identification Program framework runs the identity-verification discipline under the USA PATRIOT Act §326 framework against the Bank Secrecy Act framework. The framework runs four data elements against each natural-person borrower — the full legal name, the residential address, the date of birth, and the taxpayer-identification-number framework. The framework runs the verification framework against a government-issued photo identification document, a knowledge-based authentication framework, or a documentary-and-non-documentary verification framework against the four data elements. The framework runs the recordkeeping framework against the verification documents on the lender’s compliance file for the retention cycle defined under the Bank Secrecy Act framework.

The beneficial-ownership framework

The beneficial-ownership framework runs the FinCEN Beneficial Ownership Information framework against the entity-borrower cycle on the Corporate Transparency Act framework. The framework runs the verification framework against the legal-entity borrower — limited liability company, corporation, limited partnership — on each natural-person beneficial owner who runs the substantial-control framework against the entity or runs the ownership-interest framework above the FinCEN-defined ownership threshold. The framework runs the verification framework against the same four data elements that run against the Customer Identification Program framework — full legal name, residential address, date of birth, and taxpayer-identification-number framework. The framework runs the FinCEN BOI report framework against the entity-formation cycle and against the beneficial-ownership-change cycle.

The OFAC sanctions-screening framework

The OFAC sanctions-screening framework runs the Office of Foreign Assets Control framework against the Specially Designated Nationals and Blocked Persons List on each borrower, each entity, and each beneficial owner. The framework runs the sanctions-screening framework against the consolidated-sanctions-list framework — the SDN list, the Sectoral Sanctions Identifications list, and the Non-SDN Palestinian Legislative Council list. The lender runs the sanctions-screening framework at the loan-boarding cycle, runs the screening framework against the same borrower and beneficial-ownership data on the recurring cycle, and runs the screening framework against the OFAC framework on the wire-transfer cycle and the borrower-payment cycle. The framework runs the sanctions-hit response framework against the OFAC reporting framework and runs the wire-blocking framework against the OFAC blocked-transaction framework.

The taxpayer-identification-number framework

The taxpayer-identification-number framework runs the IRS framework against the borrower-identification cycle and against the IRS Form 1098 mortgage-interest-reporting framework on the recurring cycle. The framework runs the Form W-9 collection framework against the United States borrower and runs the Form W-8BEN collection framework against the foreign borrower. The framework runs the IRS TIN-matching framework against the borrower’s name and taxpayer-identification number on the IRS framework. The framework runs the backup-withholding framework against the borrower on a TIN-matching-failure cycle. The lender runs the TIN-verification framework against the loan-boarding cycle so the Form 1098 framework runs against the IRS framework without a backup-withholding event on the year-end reporting cycle.

The entity-authority-documentation framework

The entity-authority-documentation framework runs the signer-authority framework against the entity borrower on the loan-boarding cycle. The framework runs the documentation framework against four entity types. The limited liability company framework runs the articles-of-organization framework, the operating-agreement framework, the certificate-of-good-standing framework, and the manager-or-member-resolution framework against the signer-authority cycle. The corporation framework runs the articles-of-incorporation framework, the bylaws framework, the corporate-resolution framework, and the incumbency-certificate framework against the signer-authority cycle. The limited partnership framework runs the certificate-of-limited-partnership framework, the limited-partnership-agreement framework, and the general-partner-authority framework against the signer-authority cycle. The trust framework runs the certification-of-trust framework, the trust-agreement framework, and the trustee-authority framework against the signer-authority cycle.

The document-authentication framework

The document-authentication framework runs the identity-document framework against the verification cycle on the loan-boarding framework. The framework runs against three authentication frameworks. First, the documentary-verification framework runs the government-issued photo-identification framework — state-issued drivers license, state-issued identification card, United States passport, foreign passport with the I-94 framework — against the in-person or notarized verification framework. Second, the knowledge-based-authentication framework runs the identity-quiz framework against the borrower on the consumer-reporting-agency framework. Third, the biometric-verification framework runs the facial-recognition framework against the live-selfie framework on the identity-document framework. The lender runs the multi-factor framework against the documentary, knowledge-based, and biometric frameworks on the higher-risk borrower framework.

The loan-boarding identity-verification checklist

The loan-boarding identity-verification checklist runs the framework against ten document categories on each new loan. The lender runs the borrower-identity framework — drivers license, passport, or state identification — against the Customer Identification Program framework. The lender runs the entity-formation framework — articles of organization, articles of incorporation, certificate of limited partnership, trust certification — against the entity-borrower framework. The lender runs the entity-governance framework — operating agreement, bylaws, partnership agreement, trust agreement — against the signer-authority framework. The lender runs the signer-authority framework — corporate resolution, manager resolution, partnership consent, trustee certification — against the loan-document-execution framework. The lender runs the FinCEN BOI framework against the beneficial-ownership framework on the entity borrower. The lender runs the OFAC framework against the sanctions-screening framework on each natural person and each entity. The lender runs the Form W-9 or Form W-8BEN framework against the taxpayer-identification-number framework. The lender runs the TIN-matching framework against the IRS framework. The lender runs the address-verification framework against the residential-address framework on the borrower. The lender runs the audit-trail framework against each verification step on the lender’s servicing platform.

The audit-trail framework

The audit-trail framework runs the verification-recordkeeping framework against the loan-boarding cycle. The framework runs five elements against the lender’s servicing platform. First, the framework runs the verification-document framework against the document-storage framework on the loan file. Second, the framework runs the verification-method framework — documentary, non-documentary, knowledge-based, biometric — against the verification-log framework. Third, the framework runs the verification-date framework against the recordkeeping framework on the loan file. Fourth, the framework runs the verification-officer framework against the lender’s personnel-accountability framework. Fifth, the framework runs the exception-and-escalation framework against the verification-failure cycle. The framework runs the recordkeeping framework against the regulatory-retention cycle on the Bank Secrecy Act framework. The framework runs the beneficial-ownership recordkeeping cycle on the Corporate Transparency Act framework. The framework runs the taxpayer-identification recordkeeping cycle on the IRS framework.

Where private lenders run thin

Private lenders run the loan-boarding framework on a thin identity-verification framework when the framework runs against the borrower’s drivers license alone — the framework runs the Customer Identification Program data elements against the document framework but the framework runs against the OFAC framework, the FinCEN BOI framework, the entity-authority framework, and the TIN-matching framework on a thin discipline. The framework runs the boarded-loan framework against the wire-fraud framework, the signer-authority framework, and the IRS Form 1098 framework on a recurring cycle. The lender that runs the identity-verification framework against the ten-document framework on the loan-boarding cycle runs the audit framework, the compliance framework, and the secondary-market framework against the lender’s loan portfolio on a thicker discipline.

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Identity verification at loan boarding runs against the regulatory framework, the wire-fraud framework, the IRS reporting framework, and the secondary-market framework on the lender’s servicing platform. Note Servicing Center runs the third-party loan-servicing framework against the identity-verification framework, the document-collection framework, the Form 1098 framework, and the audit-trail framework on the loan-boarding cycle.

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Frequently Asked Questions

What is the Customer Identification Program framework?

The Customer Identification Program framework runs the identity-verification framework under the USA PATRIOT Act §326 framework against the Bank Secrecy Act framework. The framework runs four data elements against each natural-person borrower — full legal name, residential address, date of birth, and taxpayer-identification-number framework — and runs the verification framework against a government-issued photo-identification document or a documentary-and-non-documentary verification framework.

What is the FinCEN Beneficial Ownership rule?

The FinCEN Beneficial Ownership Information rule runs the beneficial-ownership-reporting framework under the Corporate Transparency Act framework. The rule runs the verification framework against each natural-person beneficial owner who runs the substantial-control framework against the reporting entity or runs the ownership-interest framework above the FinCEN-defined ownership threshold. The rule runs the BOI report framework against the FinCEN framework on the entity-formation cycle and on the beneficial-ownership-change cycle.

What is OFAC sanctions screening?

OFAC sanctions screening runs the Office of Foreign Assets Control framework against the Specially Designated Nationals and Blocked Persons List on each borrower, each entity, and each beneficial owner. The framework runs the screening framework against the consolidated-sanctions-list framework at the loan-boarding cycle, runs against the wire-transfer cycle, and runs against the borrower-payment cycle on the recurring framework.

What is IRS TIN matching?

IRS TIN matching runs the taxpayer-identification-number verification framework against the IRS framework. The framework runs the borrower’s name and taxpayer-identification number against the IRS framework on the TIN-matching framework. The framework runs the IRS Form 1098 reporting framework against the IRS framework on the year-end cycle without a backup-withholding event when the TIN-matching framework runs clean.

What is the entity-authority-documentation framework?

The entity-authority-documentation framework runs the signer-authority verification framework against the entity borrower on the loan-boarding cycle. The framework runs against the limited liability company, corporation, limited partnership, and trust frameworks. The framework runs the formation-document framework, the governance-document framework, and the signer-authorization-resolution framework against the signer-authority cycle.

What documents run the identity-verification framework?

The identity-verification framework runs against ten document categories on each new loan — borrower identification, entity formation, entity governance, signer authority, FinCEN BOI, OFAC screening, Form W-9 or Form W-8BEN, IRS TIN matching, address verification, and the audit-trail framework on the lender’s servicing platform.

What is the audit-trail framework?

The audit-trail framework runs the verification-recordkeeping framework against the loan-boarding cycle. The framework runs the verification-document framework, the verification-method framework, the verification-date framework, the verification-officer framework, and the exception-and-escalation framework against the lender’s servicing platform on the regulatory-retention cycle.

This article is educational and does not constitute legal, regulatory, or tax advice. The identity-verification framework runs against the Bank Secrecy Act framework on the lender’s compliance cycle. The framework runs against the USA PATRIOT Act §326 Customer Identification Program framework. The framework runs against the Corporate Transparency Act beneficial-ownership framework. The framework runs against the OFAC sanctions-screening framework and the IRS reporting framework on the lender’s recurring compliance cycle. Consult qualified legal counsel and a tax adviser on the specific identity-verification framework against any private-lending operation.

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