It's important to note that our entire system IS DESIGNED to prove Ability to Repay.  To draft a policy that simply reiterates the entire process for verification represents the kind of redundancy that wakes managing the process difficult.  As a consequence this draft policy may look a little thin, but we encourage you to take the same approach by referencing the detailed processes within your operating plans.  If you are pressed to provide something more substantial, then you can fall back to the complete procedures as evidence of your Macro level compliance.  On the loan level you can obviously prove compliance because you have all of the checklists and re-verification as part of your file.  

 

For subscribers to the managed templates, you may download the new compliance module with the policy integrated. 
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