Question

Internal Controls for Bank Lending

Pacific Bank provides loans to businesses in the community through its Commercial Lending Department. Small loans (less than $100,000) may be approved by an individual loan officer, while larger loans (greater than $100,000) must be approved by a board of loan officers. Once a loan is approved, the funds are made available to the loan applicant under agreed-upon terms. Pacific Bank has instituted a policy whereby its president has the individual authority to approve loans up to $5,000,000. The president believes that this policy will allow flexibility to approve loans to valued clients much quicker than under the previous policy.
Answer the following True or False questions related to the scenario.
1. All loans have the same element of risk, so it doesn't matter if the loan is large or small.
2. Allowing the bank president to have sole authority to grant large loans is fine since he or she is president.
3. Large loans present greater risk in the event of default, therefore you should have more than one person involved in making the decision to grant a large loan.4. Having one person grant loans is good internal control.

Answer 1

1. False

The higher the figure, the higher the risk. Kindly note that loans are usually insured against default. The higher the amount insured, the higher the premium payable as insurance on such amounts.

2. False

It does not make for good internal control to have one person regardless of their position to have the final say on loans of great magnitude such as $5 Million. This can quickly degenerate into a situation where the officer involved is tempted to abuse that power. It makes for good corporate governance and risk management to ensure that the board is responsible for loans of such magnitude.

3. True

If a bank lost $100 in a thousand places, from loan default, that translates to a loss of $100,000. This relatively is large however it is small and will have less impact that a loss of a million dollars in 3 places. That's $ 3,000,000.

As already indicated, it makes for good loan disbursement governance, to ensure that there is at least two persons involved in the risk acceptance criteria (RAC) evaluation and loan disbursement process.

4. False

Separation of duties is the foundation of good internal control. It allows for greater objectivity. It is also key to carefully select signatories to loan disbursements. They have to be people of impeccable character and the company must exercise proper risk management to ensure that every protocol such as opportunity that may create the impulse or inclination to breach policy is removed completely.

Cheers!