Compliance

What an examiner actually asks for, in the order they ask for it

Not your policies. The specific loan, the specific signature, and the specific document the borrower saw.

July 14, 2026  ·  The Renny team

Lenders preparing for an examination often over-invest in the policy binder and under-invest in the ability to produce a single file. The binder establishes intent. The file establishes what happened. An examination is mostly about the second.

The sequence

• A sample. Usually a list of loans selected by the examiner, not by you, from a period they choose.
• For each one: evidence of authorization. Not that a signature exists — what the borrower was shown when they gave it.
• Evidence the merchant was eligible. Vetted and trained before origination, not afterwards.
• The complaint record. Every request, when it was acknowledged, how it was resolved, and how long that took.
• Evidence nothing was changed. Whether the record could have been altered after the fact, and how you would know.

Notice that four of the five are per-loan artifacts, and the fifth is a property of your system rather than a document you can write.

The question that causes the most damage

It is rarely "do you have a signature". It is "what did the borrower see". A signature attached to a document you cannot reproduce is close to worthless, because the dispute is almost never about whether they signed. It is about whether they understood what they were signing.

Answering that requires a fingerprint of the exact document presented, stored at the moment of signature, so the copy you produce later can be proven identical.

The dispute is not "did they sign". It is "did they know". Only one of those is answerable from a signature block.

What good looks like

One artifact per loan that contains all of it: each signature with its time, its network address, its authentication method, and the fingerprint of what was presented; the merchant's standing on that date; every event in sequence; and any dispute and how it was closed.

Generated from the live record rather than stored, so it cannot have drifted from the data. If it is assembled by hand from four systems the week the notice arrives, you are not answering the question — you are constructing an answer, and the construction is itself a finding.