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Commercial Loans Underwriting that Satisfies NCUA



# Mastering Commercial Loan Underwriting: Insights from an NCUA Expert


In the world of credit unions, commercial lending presents both opportunities and challenges. To navigate this complex landscape successfully, it's crucial to understand the nuances of loan underwriting that not only serve your members but also satisfy NCUA requirements. In a recent episode of "With Flying Colors," host Mark Treichel sat down with Vin Vieten, former NCUA Senior Credit Specialist, to discuss best practices in commercial loan underwriting. Here are the key takeaways from their insightful conversation.


## The Importance of Consistent Financial Analysis


One of the cornerstones of effective commercial lending is a thorough and consistent approach to financial analysis. Vieten emphasizes the need for a structured methodology that all lenders within an institution should follow. This consistency ensures fairness to borrowers and helps train board members and senior management who may not be well-versed in commercial lending.


Key components of a robust financial analysis include:


1. Examining at least three years of financial performance to establish trends

2. Analyzing income statements, balance sheets, and cash flow statements

3. Understanding the story behind the numbers, including reasons for significant changes


Vieten suggests that lenders should view this analysis as a value-added service for borrowers. By providing an expert financial review at least annually, credit unions can deepen their relationships with members and potentially identify areas for improvement in the borrower's business.


## Crafting Effective Credit Proposals


A well-organized credit proposal is crucial for efficient decision-making and regulatory compliance. Vieten recommends including the following elements in every credit proposal:


1. A clear description of the borrower, including ownership structure and business operations

2. Industry analysis and market position

3. Repayment ability assessment

4. A summary of the total relationship exposure, including all direct and related debt

5. Assigned risk rating with justification

6. Exceptions to policy, clearly highlighted on the cover page


By presenting this information in a logical, consistent format, credit unions can ensure that all decision-makers have a comprehensive understanding of the proposed loan and its associated risks.


## The Philosophy of Global Cash Flow Analysis


Global cash flow analysis is a critical component of risk assessment in commercial lending. This process involves examining not just the borrower but also related entities and guarantors to understand the overall financial picture.


Vieten emphasizes that the depth of global cash flow analysis should be driven by the complexity and risk level of the transaction, not just regulatory requirements. He advises:


1. Focus on understanding the true risk associated with the loan

2. Consider how stresses on related entities might impact the borrower

3. Use the analysis to inform loan structuring and covenants

4. Document your approach and findings thoroughly


While the NCUA regulation provides guidelines, Vieten stresses that the primary goal should be to make sound lending decisions based on a comprehensive risk assessment.


## The Question of Guarantees


An interesting point of discussion was the NCUA's stance on guarantees for commercial loans. While not explicitly required in all cases, Vieten clarifies that the default expectation is to obtain guarantees. If a guarantee is not obtained, the credit union must document strong reasons offsetting this additional risk in the credit proposal.


## Conclusion: Balancing Risk and Opportunity


Commercial lending offers credit unions a pathway to growth and deeper member relationships. However, it requires a thoughtful, consistent approach to underwriting that balances risk management with member service. By implementing robust financial analysis processes, crafting comprehensive credit proposals, and conducting thorough global cash flow assessments, credit unions can build a strong commercial lending program that satisfies both member needs and regulatory requirements.


Remember, the goal is not just to comply with NCUA regulations but to truly understand and manage the risks associated with each loan. By focusing on this broader perspective, credit unions can make informed decisions that benefit both the institution and its members in the long run.


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