The Federal Reserve and other banking agencies issued a policy statement covering commercial real estate loans and loan workouts in October 2009 – one of a series of actions taken to support sound bank lending. 2 This guidance urges both lenders and bank examiners to take a balanced approach in assessing borrowers’ debt servicing capacity and to make realistic assessments of collateral values.
Inspections are used to verify the correctness of the reporting process established by intermediaries subject to the reporting requirement and their compliance with the obligation to identify, record and report suspicious transactions and to submit the aggregate data prescribed by anti-money-laundering legislation. 4.