WorkflowCommercial & Corporate Lending

The complete guide · October 2026

The commercial credit memo, explained.

A credit memo is the written case a bank makes before it lends to a business: what the borrower asks for, how it will repay, what secures the loan, who stands behind it, where the deal departs from the bank's own rules and what risk grade it deserves. A credit analyst writes it from the borrower's file, and a manager, an approver or a loan committee decides on it. The hard part is keeping every figure in it true while the deal keeps changing.

This guide is for anyone who writes, reviews, approves or pays for credit memos: commercial credit analysts and underwriters, underwriting managers, relationship managers, chief credit officers and loan committee members, credit administration and loan review, and the leaders deciding whether to automate the work. No background needed.

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A quick example · fictional

Imagine you are a senior commercial credit analyst at a community bank in Grand Rapids, Michigan. It is Monday, October 12, 2026. Brennick Precision Components, a family-owned machine shop and a customer since 2014, wants $19 million: a renewed $8 million line of credit, $6.8 million for new machines and $4.2 million to refinance its plant. Your memo is 14 pages long and goes to loan committee on Thursday. On page 1 it says the owners and the company together cover their debt payments 1.42 times, against a bank minimum of 1.20.

At 9:05 a.m. the borrower's accountant sends the final 2025 tax forms for the two owners. The cash the company paid them to cover their income tax was bigger than the estimate in the June statements.

June interim statements · p. 3
Line
Tax distributions
Basis
Estimate
Amount
$1,050,000
Used in
Your draft memo
2025 Schedules K-1 · p. 2
Line
Tax distributions
Basis
Final, from the CPA
Amount
$1,717,000
Arrived
Monday, 9:05 a.m.
1.42x in the draft1.18x with the K-1sthe bank's minimum is 1.20x.

That one figure, $667,000 higher, sits under twelve other numbers in the memo: the cash left for the bank, both coverage ratios, the stress test, the covenant cushion, a line of the grade scorecard. Coverage for the owners and the company together now sits below the 1.20 minimum, which creates a new policy exception that needs its own reason and its own fix. By hand, you search fourteen pages for every place the old number lived.

A careful memo catches every number that rests on a late figure, and the new exception it creates, before the committee reads page 1.

Credit memo automation guide
Part A · Understand it

Writing the commercial credit memo: its sections, its numbers and the rules it answers to

The sections, the documents, the cash flow arithmetic, policy exceptions, the risk grade, renewals, the common errors and the market, explained without selling anything. If you are new to commercial credit, start here.

01 · In plain words

What a credit memo is: the written case an approver reads before saying yes to a loan

When a business asks a bank for a loan, nobody at the bank decides on a feeling. Someone has to put the case in writing, so that the people with the authority to say yes can read it, question it and sign it. That document is the credit memo. Banks also call it a credit memorandum, a credit write-up, a credit presentation, a loan committee memo or a loan approval memo. It says what the borrower wants and why, how the loan will be repaid, what happens if it is not, and what the bank is accepting by lending.

The memo comes after the numbers. First, an analyst copies the borrower's tax returns and accountant's statements into the bank's own template, a job called spreading. The memo then turns that spread into an argument.

It describes the business and its owners, the industry, the trend in sales and profit, the cash left each year to pay lenders, the collateral, the guarantors, the loan's terms and covenants, every place the deal departs from the bank's credit policy, the main risks with what offsets each one, a proposed risk grade, and the conditions of approval. A memo for a mid-sized business loan can run to a dozen pages or more.

Federal safety-and-soundness standards describe what that written case must do. Loan documentation should "Enable the institution to make an informed lending decision" and "Identify the purpose of a loan and the source of repayment, and assess the ability of the borrower to repay the indebtedness in a timely manner". Underwriting should consider, "prior to credit commitment", the guarantor, the collateral and "the borrower's character and willingness to repay as agreed".1 In most banks, those words are met in the memo.

What makes the work hard is that the memo depends on documents that keep arriving and figures that keep moving. The relationship manager reprices a loan, the appraiser's value comes in, the borrower's accountant sends final tax forms. Each change ripples through the cash flow, the ratios, the exceptions, the grade and the one-paragraph recommendation that every approver reads first. A memo that is right on Monday can be wrong by Tuesday, and still read well.

One $19 million request, from term sheet to committee

  1. The request and the term sheetThe relationship manager agrees the amounts, rates and terms with the borrower: $19 million in three loans, in our example.
  2. The file and the spreadStatements, tax returns, the appraisal and the owners' personal statements come in; an analyst spreads them and a reviewer approves the spread.
  3. The credit memoThe analyst writes the case, section by section, and keeps it true as late documents arrive.
  4. Review and approvalAn underwriting manager reviews the memo; an officer within authority, or a loan committee, decides and sets the grade.
  5. Closing, then the annual reviewConditions are met and the loan funds. Next year's renewal starts from this memo.

Step 3 is the subject of this guide. The people, companies and figures in the example are fictional.

Credit memo surprises: no template, a dozen moving figures

No regulator publishes a memo template

The closest federal text is the SBA's list of what "the Lender's credit memorandum and analysis must address" for its loans.2 Everything else, the sections, their order and the voice, is the bank's own.

One late figure moves a dozen others

Cash flow sits at the top of a chain: two coverage ratios, a stress case, a covenant, an exception, the grade and the recommendation all hang from it. The OCC calls shortfalls in cash flow "usually the most obvious indications of a problem credit".3

A good yield is no excuse

Examiners write that "receiving a high yield on a loan with otherwise liberal underwriting is generally not a sufficient mitigating factor".4 Each policy exception needs a mitigant the bank can check or enforce.

Nobody measures how long memos take

We found no regulator, statistical agency or academic study that measures hours per memo or how often memos carry a stale number. Vendor figures come without a method. Your own baseline is the only one you can defend.

Spread, debt service coverage, policy exception, risk grade

Spread

The bank's grid of a borrower's figures, its own lines, years side by side. The memo is written from it.

Debt service coverage

Cash available for debt service divided by the loan payments due. 1.25x means $1.25 of cash for every $1.00 owed.

Policy exception

A place where the deal breaks a limit in the bank's credit policy, such as loan to value above 75%. It needs a reason and an approver.

Risk grade

The bank's rating of the credit on its own scale, often 1 to 9 or 1 to 10, proposed in the memo and set by the approver.

Fourteen terms are defined in the one-page summary.

02 · The twelve sections

What goes in a commercial credit memo, section by section, and the document each is written from

In shortA workable memo has one section for each question an approver asks, in the order they ask it, and each section can be traced to named documents. Banks name and order the sections of their credit memo template differently. The twelve below follow the sample bank's template used throughout this guide, and they cover what the SBA and OCC texts ask for.

#SectionThe question it answersWritten from
1Request and recommendationWhat do we approve, why, and who must sign?Term sheet, every later section
2Borrower and managementWho is this business, and who runs it?Prior memo, call reports, appraisal, owners' statements
3Industry and marketWhat could change its sales?Backlog report, customer concentration, call reports
4Financial analysisWhy are the numbers what they are, and where are they heading?Approved spread, audited statements, interims
5Cash flow and debt serviceCan the business, and its owners, carry this debt?Spread, interims, K-1s, personal returns
6CollateralWhat does the bank recover if cash flow fails?Appraisal, field exam, equipment quotes
7GuarantorsWho else stands behind the loan, and with what?Personal financial statements, brokerage and bank statements
8Structure, covenants and pricingWhat terms protect the bank, and with how much room?Term sheet, policy, spread
9Policy exceptionsWhere does the deal break policy, and why is that acceptable?Credit policy, the sections above
10Key risks and mitigantsWhat could go wrong, and what offsets each risk?Every section; each mitigant with its page
11Risk gradeWhat grade, and the reason for each factor?Scorecard, prior memo, spread
12Conditions of approvalWhat must be true before and after funding?Exceptions, mitigants, policy
Financial analysis, cash flow and collateral answer every rule; exceptions answer only the examiners

Does each text ask, in its own words, for what this section holds? Safety-and-soundness standards, the OCC's approval-package tests, the SBA 7(a) memo list, and the OCC's rating-credit-risk test

NoYes
Safety and soundnessOCC approval packageSBA 7(a) memo listOCC rating test1 Request and recommendationYesYesYesNo2 Borrower and managementYesNoYesNo3 Industry and marketNoNoYesYes4 Financial analysisYesYesYesYes5 Cash flow and debt serviceYesYesYesYes6 CollateralYesYesYesYes7 GuarantorsYesYesYesNo9 Policy exceptionsNoYesNoNo10 Risks and mitigantsNoYesNoYes11 Risk gradeNoYesNoYes

Our reading of the sources 1,4,2,3 · Our reading of each text; sections 8 and 12 are bank practice the texts touch only in passing. Your policy may ask for more.

Show the numbers
Safety and soundnessOCC approval packageSBA 7(a) memo listOCC rating test
1 Request and recommendationYesYesYesNo
2 Borrower and managementYesNoYesNo
3 Industry and marketNoNoYesYes
4 Financial analysisYesYesYesYes
5 Cash flow and debt serviceYesYesYesYes
6 CollateralYesYesYesYes
7 GuarantorsYesYesYesNo
9 Policy exceptionsNoYesNoNo
10 Risks and mitigantsNoYesNoYes
11 Risk gradeNoYesNoYes

The test every sentence must pass: could a reviewer confirm it alone?

Read any sentence in a draft and ask: could the underwriting manager confirm it without asking the analyst? "Management is experienced" fails, because no page says so. "Daniel Brennick, 61, owns 62% and has been with the company for 28 years; key-man life insurance of $5 million is assigned to the bank" passes, because each claim points to a document a reviewer can open. The OCC names the failure examiners write up: approval documentation that "lacks sufficient analysis of financial trends, primary and secondary repayment sources, industry trends, and risk mitigants". The same booklet sets the scale of the job: "The level of analysis should be commensurate with the level of risk."3

Committees also need the information condensed. Liberti and Petersen describe a loan approval committee with "limited time and attention to devote to each decision", so "decision makers need the information to be boiled down to what is important".5 That is why section 1 is written last and read first, and why every figure in it must match the section it comes from.

A search trap. In accounting software, a "credit memo" is a note that reduces what a customer owes. This guide is about the other one: the credit memorandum a bank writes before it lends to a business.
03 · The rules and their dates

The rules a credit memo answers to, and what changed between December 2025 and October 2026

Status as of October 2026

In shortNo federal rule prescribes a memo. Safety-and-soundness standards require documentation that supports an informed decision, examiners test the approval package against four expectations, and the SBA lists what its lenders' memos must address. In the last eleven months four of those texts were withdrawn, replaced or rewritten (the leveraged lending guidance, the model risk guidance, the OCC's lending booklet and SBA's SOP), and the Federal Reserve spoke on AI in credit decisions.

Four texts behind the credit memo were withdrawn, replaced or rewritten between December 2025 and October 2026
  1. Dec 10, 2010Appraisal guidelines

    Review the appraisal before the final credit decision.

  2. Jul 6, 2023Global coverage defined

    The interagency workout statement: borrowers' and guarantors' cash flow against their combined obligations, contingent ones included.

  3. Dec 5, 2025Leveraged lending guidance withdrawn

    The OCC and FDIC keep one duty: compare a leveraged borrower's performance with its projections.

  4. Jan 12, 2026Shared credits review

    8.6% of $6.9 trillion of large syndicated commitments rated below pass.

  5. Apr 17, 2026SR 26-2 replaces SR 11-7

    New model risk guidance; generative AI outside its scope.

  6. Jul 2026New OCC lending booklet

    Lending and Loan Portfolio Risk Management, Version 1.0, with its approval-package tests.

  7. Jul 14, 2026Fed on AI in credit

    AI closer to credit decisions faces more legal compliance challenges.

  8. Oct 1, 2026SBA SOP 50 10 8.1

    A technical update of the SOP; its 7(a) memo list still names distributions for S corporation taxes among the adjustments to justify.

Source 6,7,8,9,10,4,11,2,12

Show the numbers
WhenWhat
Dec 10, 2010Appraisal guidelines
Jul 6, 2023Global coverage defined
Dec 5, 2025Leveraged lending guidance withdrawn
Jan 12, 2026Shared credits review
Apr 17, 2026SR 26-2 replaces SR 11-7
Jul 2026New OCC lending booklet
Jul 14, 2026Fed on AI in credit
Oct 1, 2026SBA SOP 50 10 8.1
Jan 1, 2027Colorado automated-decision law
TextWhat it asks of a memoStatus
Safety and soundness, 12 CFR 30 App. ADocumentation that enables "an informed lending decision", identifies the purpose and source of repayment, and considers the guarantor, collateral and character "prior to credit commitment".1Current
OCC, Lending and Loan Portfolio Risk ManagementThe approval package should "provide credit decision makers with a thorough analysis of the borrowers' and guarantors' sources of repayment", "include information about previous and related transactions and performance, if applicable", "contain a comprehensive analysis of key credit risks and mitigating factors" and "provide appropriate support for the credit approval, risk rating, and accrual treatment".4Version 1.0, July 2026
OCC, Rating Credit RiskAnalysis "commensurate with the level of risk"; examiners compare internal ratings with their own and are "most concerned when rating inaccuracies understate risk".3Current; edited March 2025
Fed examination manualThe credit file should "state the purposes of all loans" and "identify the collateral and state its value and the source of the valuation"; the reason for each policy exception "detailed in writing, submitted for approval to a designated authority, and documented in the loan file".13Current
Real estate lending guidelines, 12 CFR 34A loan outside the bank's own real estate limits "should be supported by a written justification that clearly sets forth all of the relevant credit factors".14Current
SBA SOP 50 10 8.1History and management, three years of financials, EBITDA with a "Justification for additions and subtractions to cash flow", global cash flow, collateral, insurance and the "Lender's rationale for recommending approval".2Effective October 1, 2026
OCC and FDIC, leveraged lending"Each bank should determine its own definition of a 'leveraged loan'", and compare a leveraged borrower's "past and current performance compared with projections".82013 guidance withdrawn December 5, 2025
SR 26-2 and OCC Bulletin 2026-13Spreadsheet arithmetic and fixed rules are outside the definition of a model; generative AI is outside the guidance's scope.10,15April 17, 2026
NCUA, 12 CFR 723.4A credit union's commercial loan policy must address "The level and depth of financial analysis necessary" and borrower projections when history does not support the debt.16Current
Regulation B, 12 CFR 1002.9A business declined for credit can ask for "a statement of specific reasons" within 60 days; the reasons come from the analysis.17Current

What the SBA's memo list adds, as of October 2026

For every standard 7(a) memo
  • The memo "must address the Applicant's ability and likelihood to repay the loan from the cash flow of the business and past performance".2
  • Adjustments to cash flow must be justified one by one, among them "Unfunded capital expenditures", "Non-recurring income" and "Distributions for S-Corp taxes".2
  • Without reasonable assurance of repayment from cash flow, "the loan request must be declined, regardless of the collateral available or outside sources of repayment".2
What it leaves to the lender
  • The format. "7(a) Small and SBA Express Lenders may use their own forms, internal credit memoranda", following SBA's requirements.2
  • The voice, order and length of the sections.
  • Conventional loans entirely: the SBA list is a good skeleton for any bank, but only SBA loans are bound by it.
Two claims to correct. Some current articles still say "SR 11-7 requires" model validation of credit tools; since April 17, 2026, SR 26-2 has replaced it.10 And some cite the OCC lending booklet as June 2026; its cover reads Version 1.0, July 2026.4
04 · The deal file

The deal file behind a memo: thirty-nine documents from six sources, and the ones that arrive late

In shortA memo for an owner-managed business draws on documents produced by people the credit team does not direct: the borrower, its accountant, the appraiser, the field examiner, the guarantors and the relationship manager. Most arrive on time. The ones that arrive after drafting has started, or that disagree with another document, cost the most.

Collateral and tax documents fill more than half of the file's 586 pages

Pages in the Brennick deal file by group of documents, 39 documents in all

Collateralappraisal 86 pages, environmental 38, field exam 31176 pages
Tax returns and K-1sbusiness and personal returns, 2024 and 2025163 pages
Prior memo and policycredit policy 64 pages110 pages
Financial statementsthree audits and the June interims96 pages
Guarantorswhere the conflict was24 pages
Deal documentsterm sheet, call report, backlog, spread17 pages

Fictional example from this guide · Fictional example. The memo's 130 cited numbers point to 16 of the 39 documents; the 24 guarantor pages held the conflict below.

Show the numbers
GroupPages
Collateral176 pages
Tax returns and K-1s163 pages
Prior memo and policy110 pages
Financial statements96 pages
Guarantors24 pages
Deal documents17 pages
InputOwnerHow it arrives late
Request and term sheetRelationship managerAmount or rate renegotiated after drafting
Statements and returnsBorrower and its CPAFinal K-1s after the interim estimate
AppraisalAppraiser and the bank's reviewerValue usable only after review
Field examField examinerEligible inventory changes the borrowing base
Personal statementsGuarantorsA later brokerage statement contradicts them

The Federal Reserve's examination manual lists what a credit file should hold before credit is granted: it should "identify the borrower's business or occupation", "document the borrower's past and current financial condition", "state the purposes of all loans granted to the borrower, the sources of repayment, and the repayment programs" and "identify the collateral and state its value and the source of the valuation".13 Each clause names an input someone outside the credit department produces.

The appraisal sets the earliest date a memo can be final

The interagency appraisal guidelines expect a bank to review appraisals and evaluations "prior to a final credit decision".6 In our example, the plant's appraisal was effective September 21, 2026 at $5,400,000, and the bank's appraisal desk reviewed it on September 29, eight days before the October 7 term sheet. That value sets the real estate loan to value at 77.8%, against a 75% policy maximum, so it creates a policy exception before any analysis is written.

When two documents disagree, someone has to choose, and say why

Personal financial statement · June 30, 2026

Signed by the guarantor. Cash and marketable securities as stated: $1,920,000.

Brokerage statement · August 31, 2026

From the broker. $1,410,000, after a $520,000 withdrawal on July 14 for a house build.

Either liquidity figure clears the $1.9 million rule, so the wrong one would pass unnoticed

Combined guarantor liquidity against the sample bank's requirement of 10% of the $19,000,000 guaranteed, $ thousands

With the signed statementJune 30, 2026$2,550
With the brokerage statementAugust 31, 2026, the figure used$2,040
Policy requirement10% of the guarantee$1,900

Fictional example from this guide · Fictional example. The gap between the two figures is $510,000.

Show the numbers
LiquidityAmount
With the signed statement$2,550
With the brokerage statement$2,040
Policy requirement$1,900

Both figures clear the sample bank's guarantor liquidity rule: 10% of the $19,000,000 guaranteed, or $1,900,000, against combined liquidity of $2,550,000 with the signed statement or $2,040,000 with the brokerage statement. So a draft that used the first figure it read would have overstated liquidity by $510,000 and still passed every test. Nobody would have noticed. The safer rule is to use neither figure until a person chooses one and writes down the reason, here the later, third-party statement.

Fictional example. Guarantors matter in practice: among small firms with debt, 59% used a personal guarantee to secure it, in the Federal Reserve Banks' 2026 report on their 2025 survey.18

05 · Cash flow and stress

Cash available for debt service, coverage and the stress case, worked through one $19 million request

In shortStart from EBITDA, take off the cash the bank decides is unavailable, and divide what is left by every loan payment the borrower will owe, the new loans included. Then add the guarantors, and test the result against a bad year. Every deduction needs its reason in the memo, and every ratio must name the spread version it came from.

Debt service coverage = (EBITDA − unfinanced capital spending − tax distributions − other distributions) ÷ pro forma debt service

The SBA puts the deductions in its memo list, naming "Unfunded capital expenditures", "Expenses and distributions" and "Distributions for S-Corp taxes" among the adjustments a lender must justify.2 The interagency definition of global debt service coverage adds the owners: cash flows "generated by both the borrower(s) and guarantor(s), as well as the combined financial obligations (including contingent obligations)".7

A credit memo example, worked through: the trailing twelve months to June 30, 2026, spread version 3

LineWhere it comes fromAmount
EBITDAApproved spread, trailing twelve months$6,050,000
Less unfinanced capital spendingJune interims and capital plan−$640,000
Less tax distributions to the ownersJune interims, an estimate−$1,050,000
Less other distributionsJune interims−$480,000
Cash available for debt service$3,880,000
Equipment loan, $6.8M, 7 years at 7.15%Term sheet$1,237,555
Real estate loan, $4.2M, 20-year amortization at 6.85%Term sheet$386,226
Line interest, $5.6M drawn at 7.05%Term sheet$394,800
Capital leasesDebt schedule$412,000
Pro forma debt service$2,430,581
Debt service coverage$3,880,000 ÷ $2,430,581; policy minimum 1.25x1.60x
Global coverage+ $240,000 guarantor income − $210,000 living costs; + $318,000 personal debt service; minimum 1.20x1.42x
Stress: EBITDA 20% lower$2,670,000 ÷ $2,430,5811.10x

Fictional example; every payment recomputed from the stated terms. Leverage is $17,960,000 of senior funded debt over $6,050,000 of EBITDA, or 2.97x, against a 3.00x policy maximum.

Debt service takes 40% of EBITDA and the owners' distributions a quarter, leaving a $1.45 million cushion

Where $6,050,000 of trailing EBITDA goes, spread version 3

Pro forma debt serviceTax distributionsOther distributionsUnfinanced capital spendingCushion above debt service
EBITDA, $6,050,000$2.4M$1.1M$640K$1.4M

Fictional example from this guide · The cushion is cash available for debt service, $3,880,000, less debt service. It is the room the coverage ratio measures.

Show the numbers
Pro forma debt serviceTax distributionsOther distributionsUnfinanced capital spendingCushion above debt service
EBITDA, $6,050,000$2.4M$1.1M$480K$640K$1.4M

Debt service by loan: where the payments come from

The new equipment loan is half of the borrower's yearly debt service

Pro forma annual debt service, $2,430,581 in all

Equipment term loan, new7 years, fixed 7.15%$1.2M
Capital leases, existingto 2029$412K
Line of credit interestfloating; +200 bps costs $112,000$394.8K
Real estate term loan20-year amortization$386.2K

Fictional example from this guide

Show the numbers
LoanAnnual debt service
Equipment term loan, new$1.2M
Capital leases, existing$412K
Line of credit interest$394.8K
Real estate term loan$386.2K

Why the stress case belongs in the memo

A coverage ratio is a single year. The question an approver asks is how much bad news it can absorb. The OCC expects projections "analyzed under multiple scenarios — downside, breakeven, best case, most likely case — and stress-tested periodically", and more complex credits to carry "sensitivity analysis".3

The sample bank runs three cases on every memo: EBITDA 10% lower, EBITDA 20% lower, and rates 200 basis points higher on the floating line. At version 3 of the spread, the 20% case leaves coverage at 1.10x, above 1.00x. Turned into dollars, the cushion above a 1.25x minimum is $842,000 of cash available ($3,880,000 less 1.25 × $2,430,581): about 14% of EBITDA could disappear before the business ratio breaks policy.

Name the version every time. A memo that quotes "1.60x" in the summary and "1.32x" in the cash flow section is a typical inconsistency a reviewer finds. It happens when sections are edited at different times. Writing "spread v3" or "spread v4" beside each ratio makes the mismatch visible.
06 · One late figure

How one late tax figure moves twelve numbers, three paragraphs and a policy exception

In shortPass-through companies pay cash to their owners to cover the owners' tax on the company's profit. Interim statements estimate it; the accountant's final forms often arrive weeks later. When the final figure differs, everything built on cash flow moves, and some of it crosses a line in the credit policy.

An S corporation or partnership pays no federal income tax of its own, so it usually sends cash to its owners to pay theirs. The SBA names the line among the adjustments a memo must justify: "Distributions for S-Corp taxes".2 In our example the June interim statements estimated $1,050,000. On the Monday of committee week the accountant's 2025 Schedules K-1 put it at $1,717,000, because $667,000 of extension payments went out in September.

One K-1 figure moves seven sections of the memo before it reaches the recommendation
  1. 1The K-1s arrive

    Tax distributions of $1,717,000, against the interim estimate of $1,050,000.

    Borrower's accountant9:05 a.m.
  2. 2Spread row 55

    The analyst enters the final figure; the spread becomes version 4.

    Credit analyst9:06 a.m.
  3. 3Cash available

    Falls by exactly $667,000, from $3,880,000 to $3,213,000.

    §1, §5
  4. 4Coverage and stress

    1.60x to 1.32x; global 1.42x to 1.18x; stress case 1.10x to 0.82x.

    §1, §5, §8
  5. 5A new exception

    Global coverage below the 1.20x minimum in policy §4.2.

    §9
  6. 6A new mitigant

    Other distributions suspended until global coverage reaches 1.25x for two quarters.

    §10, §12
  7. 7The grade

    Coverage factor moves from 4 to 5; the weighted score from 4.75 to 5.05.

    §11
  8. 8Page 1

    Every figure the committee reads first, rewritten.

    §1Accepted 9:08 a.m.

Fictional example from this guide · Fictional example, from the sample memo's change log.

Show the numbers
StepWhat happensWhoTime
The K-1s arriveTax distributions of $1,717,000, against the interim estimate of $1,050,000.Borrower's accountant9:05 a.m.
Spread row 55The analyst enters the final figure; the spread becomes version 4.Credit analyst9:06 a.m.
Cash availableFalls by exactly $667,000, from $3,880,000 to $3,213,000.§1, §5
Coverage and stress1.60x to 1.32x; global 1.42x to 1.18x; stress case 1.10x to 0.82x.§1, §5, §8
A new exceptionGlobal coverage below the 1.20x minimum in policy §4.2.§9
A new mitigantOther distributions suspended until global coverage reaches 1.25x for two quarters.§10, §12
The gradeCoverage factor moves from 4 to 5; the weighted score from 4.75 to 5.05.§11
Page 1Every figure the committee reads first, rewritten.§1Accepted 9:08 a.m.
The late K-1s push global coverage and the stress case below their minimums

Cash available per $100 of debt service, before and after the final tax figure (1.32x = $132)

Spread v3, interim estimateSpread v4, final K-1s
Business coverage (minimum $125)$160$132
Global coverage (minimum $120)$142$118
Stress, EBITDA 20% lower (minimum $100)$110$82

Fictional example from this guide · The mitigant in section 10 suspends $480,000 of other distributions: business coverage then reads 1.52x, global 1.35x, the stress case 1.02x.

Show the numbers
Spread v3, interim estimateSpread v4, final K-1s
Business coverage (minimum $125)$160$132
Global coverage (minimum $120)$142$118
Stress, EBITDA 20% lower (minimum $100)$110$82

What the change does to each kind of sentence

Numbers

Recomputed

Twelve figures in seven sections move, from cash available to the weighted grade score. Each must change everywhere it appears, including tables and the summary.

Judgments

Rewritten

"Coverage is comfortable" stops being true. The covenant cushion falls from 0.35x to 0.07x, a covenant the borrower could trip in its first weak quarter.

Structure

Added

A new exception needs its own mitigant, a condition of approval to enforce it, and a new risk in section 10. None of that existed in the draft.

A vendor article written for community bankers describes the manual version precisely: "if an interest rate changes, it may require a credit analyst to sift through many, many pages of text to update all the related numbers and calculations that use that value". It goes on: "it is unlikely that a human reviewer will consistently catch all the places values should be updated. Therefore, a new loan could be approved that should not be, or an existing loan may not be downgraded that should be."19 The article comes from a software vendor; the mechanism it describes is plain arithmetic.

Why the mitigant keeps the tax distributions. The $1,717,000 stays in the calculation because it pays the owners' tax on the company's own income; the new condition in section 12 allows tax distributions only, against the K-1s. The fix suspends the other $480,000 of distributions instead, which gives the coverage figures in the chart's note.
07 · Policy exceptions

Writing policy exceptions an examiner accepts: the limit, the actual, the mitigant and the approver

In shortAn exception is a place the deal breaks the bank's own policy. Examiners accept an exception that is identified, explained and approved. They criticize exceptions nobody identified, exceptions without a written reason, and patterns that show the policy is ignored in practice. Each exception in a memo should carry four things in one place.

The OCC's 2026 booklet is direct: "Examiners should expect to see exceptions clearly identified in the loan approval documentation along with mitigants that justify the decision to approve the loan." It also says that "Examiners should not criticize a loan solely because it has an exception", and warns that "a consistent pattern of these exceptions can reflect a critical lack of internal controls".4 The Federal Reserve's manual asks that "the reason for the exception be detailed in writing, submitted for approval to a designated authority, and documented in the loan file".13

The four parts every exception carries

1

The limit and its section

"Real estate loan to value above policy · Policy §5.1." The reader can open the policy at the right page.

2

The actual against the limit

"77.8% vs 75%." Both figures, each from a named document: $4,200,000 over the appraised $5,400,000.

3

A mitigant with its source

"Cross-collateralized with the equipment and all business assets; unlimited guarantees from both owners; owner-occupied since 1996."

And the fourth: who approves it. In the sample bank, exceptions on a credit above the chief credit officer's $15,000,000 authority are approved by the loan committee with the credit, and reported to the board quarterly.

Real estate limits: the bank's own, under the supervisory ceiling

A 75% bank limit on owner-occupied property sits ten points under the federal ceiling for improved property

Supervisory loan-to-value limits that a bank's own limits should not exceed, with the sample bank's policy limit

Raw land65%
Land development75%
Commercial construction80%
Improved property85%
Sample bank, owner-occupied (fictional)its policy §5.175%

Source 14 · The last bar is the fictional bank's own policy, shown against the supervisory limits.

Show the numbers
Loan categoryMaximum loan to value
Raw land65%
Land development75%
Commercial construction80%
Improved property85%
Sample bank, owner-occupied (fictional)75%

The interagency real estate guidelines tell banks to set "their own internal loan-to-value limits" that "should not exceed" the supervisory ones, and to support any loan outside the bank's own standards with "a written justification that clearly sets forth all of the relevant credit factors", kept "as a part of the permanent loan file". Loans above the supervisory limits should not exceed 100% of total capital in aggregate, and those secured by commercial, agricultural, multifamily or other non-1-to-4 family property should not exceed 30% of total capital.14 A memo that records the exception properly is also the bank's evidence for that count.

Three kinds of exception, and when each is written

TypeWhen it happensExamplesWhere the memo shows it
UnderwritingAt approvalCoverage, loan to value, amortization, no guarantorSection 9, with a mitigant and approver
FinancialDuring the life of the loan"Covenant breaches (even if waived)", coverage below policy at annual reviewThe renewal memo's history and section 9
Credit administrationAny timeStale statements or borrowing base certificates, missing lien filingsConditions of approval

Types and examples from the OCC's exception table.4 The booklet adds that "Unidentified exceptions are often the result of errors, miscalculations, breakdowns in the pre- or post-closing review process, or system failures".

Price belongs in the pricing paragraph. The OCC says the expectation is "for the bank to be compensated for the higher level of risk taken rather than the pricing serving as a mitigant".4 A relationship return of 16.8% against a 15% hurdle is reported there, outside section 9.
08 · The risk grade

Proposing a risk grade with a reason for every factor, and why examiners check it against their own

In shortMost banks grade commercial credits on their own scale and map the weak end to the regulators' four classes. The memo proposes a grade; the approver sets it. A grade that names each factor, its weight and its evidence survives an examiner's comparison. A bare number invites the question of who chose it, and why.

A 1998 Federal Reserve study of risk rating at the fifty largest US bank holding companies found that "Most banks require some sort of written justification of the grade as part of the loan approval package", and that ratings "are initially assigned either by relationship managers or the credit staff".20 The OCC "considers accurate classification of credit among its top supervisory priorities". To check it, examiners "review a sample of loans and compare internal bank ratings with those assigned by OCC staff", and they "should be most concerned when rating inaccuracies understate risk".3

Cash flow and leverage carry more than half of the grade's weight

The sample bank's commercial scorecard, weight by factor

Cash flow coverage: 30%Leverage: 25%Collateral: 15%Liquidity and working capital: 10%Management and industry: 10%Guarantor support: 10%
6factors
  • Cash flow coverage30%
  • Leverage25%
  • Collateral15%
  • Liquidity and working capital10%
  • Management and industry10%
  • Guarantor support10%

Fictional example from this guide

Show the numbers
PartValue
Cash flow coverage30%
Leverage25%
Collateral15%
Liquidity and working capital10%
Management and industry10%
Guarantor support10%
FactorScoreBecause
Cash flow coverage51.32x; global 1.18x
Leverage62.97x pro forma, 1.71x a year ago
Collateral5Cross-collateralized; LTV 77.8%
Liquidity and working capital4Current ratio 1.74
Management and industry5Largest customer 27% of sales
Guarantor support4Verified liquidity $2,040,000
Weighted5.05Grade 5, Acceptable; 4 in October 2024

Fictional example. 0.30 × 5 + 0.25 × 6 + 0.15 × 5 + 0.10 × (4 + 5 + 4) = 5.05.

The four regulatory classes the weak grades map to

ClassThe regulators' words
Special mention"potential weaknesses that deserve management's close attention", not yet adversely classified
Substandard"inadequately protected by the current sound worth and paying capacity of the obligor or of the collateral pledged", with "a well-defined weakness"
Doubtfulweaknesses that make collection or liquidation in full "highly questionable and improbable"
Loss"considered uncollectible and of such little value that their continuance as bankable assets is not warranted"

From the OCC's Rating Credit Risk booklet.3 Credits outside these four are "pass", which banks split into several grades of their own.

How common the weak grades are in large shared loans

About 9 in every $100 of large shared loan commitments were rated below pass in 2025
8.6 in 100

dollars of the $6.9 trillion of shared national credit commitments were special mention or classified in the 2025 review, down from 9.1%

Source 9

Show the numbers
MeasureValue
dollars of the $6.9 trillion of shared national credit commitments were special mention or classified in the 2025 review, down from 9.1%8.6 of 100

The agencies' 2025 review of shared national credits, the largest syndicated loans, covered $6.9 trillion of commitments to 6,857 borrowers. The share rated below pass fell from 9.1% to 8.6%, which the agencies attribute "primarily" to "growth in new commitments rather than an underlying improvement in credit quality".9 Examiners from three agencies rate those loans in a joint review. A community bank's exam runs the same comparison one sampled loan at a time, and a proposed grade with stated reasons is what the bank brings to it.

09 · Renewals and projections

Renewal memos: carrying the loan's history, and testing last year's projections against this year's results

In shortA large share of the memos a commercial bank writes are renewals and modifications, because business loans are renegotiated often and most lines run a year. Examiners read them as a continuation of the credit, so the memo has to show what changed since approval, how the borrower performed under each version of the terms, and whether last year's forecast came true.

5 times

the typical bank loan is renegotiated over its life, "or every nine months", with pricing, maturity, amount and covenants changed each time.21

Roberts, NBER Working Paper 20484; loans in public companies' SEC filings
<28%

of renegotiations were caused by a covenant violation or the expectation of one. Most follow changes in the borrower's needs.21

Same study
>75%

of covenant violations lead to a renegotiation, which is why a waiver belongs in the next memo.21

Same study

Smaller borrowers renew more often still: among firms with under $50 million of assets, "three-quarters of credit lines have maturity of 1 year or less at origination".22 The OCC's approval-package test asks for "information about previous and related transactions and performance, if applicable", and its exception table counts "Covenant breaches (even if waived)" as financial exceptions.4 The Rating Credit Risk booklet tells examiners to watch for "rewrites or renewals for the purpose of simply deferring a maturity" and for covenants "waived or renegotiated by the bank to accommodate a borrower's failure to maintain the original standards".3

The amendment table a renewal memo should carry

DateWhat changedWhyCovenant status thenPerformance after
Original approvalAmount, rate, covenants as approvedNew creditCompliantPrincipal repaid, coverage by year
Each renewalMaturity, rate, amountThe borrower's request or the bank'sAs testedPrincipal actually reduced?
Each waiver or resetA covenant level, a test dateA breach or a forecast breachBreached, waivedWould it pass the original covenant today?

The FDIC's manual lists "numerous renewals with little or no principal reduction; renewals that include interest" among the signs of trouble.23

Projections against actuals: the capital spending line that hides a miss

Coverage held only because capital spending was cut in half

Last year's projection against this year's actual, a generic manufacturer

Projected last yearActual this year
Revenue$48M$45.1M
EBITDA$5M$4.2M
Capital spending$1.2M$600K
Distributions$800K$800K
Cash available for debt service$3M$2.8M
Debt service$2M$2M

Illustrative · replace with your own numbers · Illustrative round numbers. Had the borrower spent the planned $1.2M, cash available would have been $2.2M and coverage 1.10x, below a 1.25x minimum.

Show the numbers
Projected last yearActual this year
Revenue$48M$45.1M
EBITDA$5M$4.2M
Capital spending$1.2M$600K
Distributions$800K$800K
Cash available for debt service$3M$2.8M
Debt service$2M$2M

Read the table from the bottom and the borrower looks fine: $2.8 million of cash for $2.0 million of debt service, 1.40x against a 1.25x minimum. Read it from the top and EBITDA missed by 16%. Coverage held because the business deferred half its capital spending. The OCC warns that "A troubled borrower will often cut capital expenditures in order to generate cash for debt service", and that "Borrowers that quickly or repeatedly fall short of their projections lack credibility".3 When the OCC and FDIC withdrew the 2013 leveraged lending guidance on December 5, 2025, they kept that comparison as a principle for leveraged borrowers: "a bank should conduct an analysis of a leveraged borrower's past and current performance compared with projections, as well as the assumptions on which the projections are based".8

Reused text is how stale facts survive. Renewal memos are often built by copying last year's memo. That saves time, and it is how a sentence about the largest customer, true two years ago, sits under this year's numbers. The fix is to mark every carried-forward passage with the memo and page it came from, and check each one against this year's file.
10 · What goes wrong

Twelve ways a credit memo misleads its approver, from stale numbers to records that were altered

In shortMemos fail in four places: in the numbers, in the documents, in the judgment, and in the controls around them. The costly failures read well. A ratio from an old spread, a liquidity figure from the wrong statement and a renewal with no history all look like ordinary sentences.

#FailureWhy it happensWhat catches it
In the numbers
1A stale figure survives a changeSections edited at different timesEvery figure linked to its source and its dependants
2Summary and body disagreeSection 1 written last, from memoryThe summary built from the sections, never typed
3Taxable income counted as cashThe wrong line of a personal return19Distributions traced to the K-1s
In the documents
4Two documents disagree, one is used silentlyThe first figure read winsA conflict rule: use neither until a person chooses
5Unreviewed appraisal valueDrafting starts before reviewReview date recorded beside the value6
6Stale statements or certificatesOld documents carried forwardDates checked against policy4
In the judgment
7The memo restates the spreadPasting replaces explainingEach paragraph ends on the consequence for repayment3
8Generic risks and mitigantsText reused across borrowersOne risk, one checkable mitigant, one source
9Price offered as a mitigantYield feels like protectionPricing kept out of section 94
In the controls
10Exceptions nobody identifiedLimits tested by eyeEvery limit tested on every memo4
11Grade with no stated reasonsThe scorecard lives in a spreadsheetA reason per factor in section 1120
12Records altered to hide weak loansOne insider, weak oversightEvery edit logged with before and after, read by someone independent
Test first for the failures that are common and change the decision
How far it moves the decision →
Plant in a test
Fix first
Sample
Automate it
Stale figureNo exception notedSilent conflictSummary mismatchGeneric mitigant
How often it happens →

Illustrative · replace with your own numbers · Positions are our judgment from the cases in this guide; no public data ranks memo failures by frequency.

Show the numbers
ItemHow often it happens (0–1)How far it moves the decision (0–1)
Stale figure0.780.78
No exception noted0.180.74
Silent conflict0.300.60
Summary mismatch0.800.27
Generic mitigant0.680.10

When the bank's own account of a loan is false

Three failures where loan records hid weak credits cost the deposit insurance fund over $1 billion

Estimated loss to the Deposit Insurance Fund

First NBC Bank, Louisiana (closed 2017)renewals and new loans used to pay old ones$996.9M
First National Bank of Lindsay, Oklahoma (2024)records altered; loss 54% of assets$42.3M
Santa Anna National Bank, Texas (2025)fraud across much of the loan book$23.5M

Source 24,25,26

Show the numbers
BankEstimated loss
First NBC Bank, Louisiana (closed 2017)$996.9M
First National Bank of Lindsay, Oklahoma (2024)$42.3M
Santa Anna National Bank, Texas (2025)$23.5M

The Inspectors General name the same gap in each. At First NBC, "Risk management deficiencies related to loan extensions and loan reviews were the most prevalent", and "Management extended new loans that were used to make payments on existing loans".24 At Lindsay, weak controls "allowed one or more Bank employees to alter Bank records and hide weaknesses in the Bank's loan portfolio from examiners".25 At Santa Anna, "a critical breakdown in the Bank's internal controls" allowed "fraudulent activity to occur that affected a substantial portion of the Bank's credit portfolio".26

What a memo can and cannot prevent. A citation proves where a number came from, and says nothing about whether the document is genuine; that takes verification at intake, such as tax transcripts and third-party statements. An edit log is a control only if someone independent reads it. What a well-built memo changes is the cost of looking: the evidence for each figure sits one step away. The FDIC's manual puts the older lesson plainly: "Lending errors frequently result because of management's failure to obtain and properly evaluate credit information".23
11 · The market

Commercial lending in 2026: rising loan balances, steadier standards and memos still written by hand

In shortUS banks hold close to $3 trillion of commercial and industrial loans, and the balance has grown through 2026. By the July 2026 survey, standards had stopped tightening and demand from larger firms had turned up. Banks still decide most business credit by people reading memos, and few had automated the memo when last surveyed.

C&I loans at US banks reached $2.96 trillion in September 2026

Commercial and industrial loans, all commercial banks, each September, $ billions

2,3702019
2,7602020
2,4172021
2,7482022
2,7612023
2,7782024
2,6912025
2,9592026

Source 27 · About $115 billion was reclassified out of C&I in January 2025, so 2025 and 2026 are not strictly comparable with earlier years.

Show the numbers
September$ billions
20192,370
20202,760
20212,417
20222,748
20232,761
20242,778
20252,691
20262,959
By July 2026 banks had stopped tightening loans to larger firms, and those firms' demand had turned up

Senior loan officers, net percent reporting tighter C&I standards and stronger C&I demand, large and middle-market firms

Tighter standards (net %)Stronger demand (net %)
-100-50050100016.1
Q2 23Q4 23Q2 24Q4 24Q2 25Q4 25Q2 26

Source 28

Show the numbers
Tighter standards (net %)Stronger demand (net %)
Q2 2346-55.6
Q3 2350.8-51.6
Q4 2333.9-30.5
Q1 2414.5-25
Q2 2415.6-26.6
Q3 247.90
Q4 240-21.3
Q1 256.29.4
Q2 2518.5-20.3
Q3 259.5-28.6
Q4 256.511.5
Q1 265.316.1
Q2 268.14.8
Q3 26016.1

Large and middle-market firms are the borrowers whose credits most often need a full memo and a committee. In the July 2026 survey, the net share of banks tightening standards for them was zero, and a net 16.1% reported stronger demand.28

Fewer than half of small-business applicants got the full amount they asked for

Outcome for applicants for a loan, line or cash advance, 2025

Full amountSome or mostNone
Applicants42%36%22%

Source 18 · Federal Reserve Banks' Small Business Credit Survey, employer firms.

Show the numbers
Full amountSome or mostNone
Applicants42%36%22%
Only 7 in 100 surveyed institutions used an automated tool to produce the credit memo in 2021
7 in 100

institutions in a vendor's survey of nearly 250 lenders and analysts generated the memo with an automated solution; nearly half did it by hand and 42% used a mix

Source 29

Show the numbers
MeasureValue
institutions in a vendor's survey of nearly 250 lenders and analysts generated the memo with an automated solution; nearly half did it by hand and 42% used a mix7 of 100

The survey behind the 7% was run by a software vendor in early 2021, so treat it as a dated snapshot. Newer figures come from vendors' own case studies. A ratings and data company reports one bank cutting corporate credit report preparation "from 20 hours to 4 hours".30 A loan-software company says a relationship review "can take a commercial credit team two full days", and "a week" for complex borrowers.31 A consultancy describes one global bank's memos at "50–60 pages".32 None publishes a method, so read them as claims to test on your own files.

The category is new enough that a market-data company launched its memo builder only on June 4, 2026, promising "in-line citations linked to exact data sources" and stating that it "is not a substitute for independent credit analysis".33

Who writes the memos

Credit analysts across all industries earned a median of $83,510 in May 2025, and about 64,390 people held the job.34 Benefits add the rest of the cost: wages were 70.0% of private employers' compensation costs in June 2026.35 At the median, a loaded analyst hour costs about $57, our arithmetic. The occupation includes consumer and trade credit analysts, so use your own pay scale where you have it.

Speed matters to borrowers too. The share of small-business applicants who went to online lenders rose from 17% in the 2020 survey to 29% in the 2025 survey.18 The FDIC's 2022 survey of small business lending found that "Three in four banks approve their typical loan within ten business days".36

12 · Automation and AI

AI-drafted credit memos: what the 2026 guidance covers, what it leaves to the bank, and why the drafter should not check itself

Status as of October 2026

In shortSoftware can index every figure in the file with its page, paste the spread's tables, describe documents, test every policy limit, draft risks and mitigants for a person to accept, and trace what a change touches. The arithmetic and rules sit outside the 2026 definition of a model, and generative AI sits outside the model guidance's scope, so governance comes from the bank's own AI, third-party and control frameworks. Decisions stay with people.

SR 26-2 excludes "simple arithmetic calculations, such as those found within spreadsheets, as well as deterministic rule-based processes and software where there are no statistical, economic, or financial theories underpinning their design or use" from the definition of a model, and puts generative AI and AI that acts on its own outside the guidance's scope because those tools "are novel and rapidly evolving".10,15 The agencies say they plan a request for information that "considers, in particular, banks' use of AI".15 Until then, buying a tool does not move the duty: third-party guidance says "the use of third parties does not diminish or remove banking organizations' responsibilities".37 The agencies proposed replacing that 2023 guidance on September 11, 2026; until a final version is issued, the 2023 text applies.38

Most of a memo tool sits outside the model guidance and inside other rules

Does each text govern this part of a memo tool you buy? The 2026 model guidance (SR 26-2), the 2023 third-party guidance, and your own credit and AI policy

NoYes
Model guidanceThird-partyYour policyIndexing figures with their pagesNoYesYesCoverage, stress and limit testsNoYesYesDrafting the sectionsNoYesYesTracing what a change touchesNoYesYesScorecard that proposes the gradeYesYesYesApproving the credit and its exceptionsNoNoYes

Our reading of the sources 10,37 · Our reading for a bought tool. A statistical scorecard may be a model at a large bank; your counsel and model risk team decide.

Show the numbers
Model guidanceThird-partyYour policy
Indexing figures with their pagesNoYesYes
Coverage, stress and limit testsNoYesYes
Drafting the sectionsNoYesYes
Tracing what a change touchesNoYesYes
Scorecard that proposes the gradeYesYesYes
Approving the credit and its exceptionsNoNoYes

What supervisors said in 2026 about AI-drafted memos

Narrow use, a person accountable. The OCC's Spring 2026 report found banks using generative AI "with usage generally limited to specific use cases with guardrails and human-in-the-loop accountability to manage risk".39
Credit decisions draw more scrutiny. The Fed's Vice Chair for Supervision said in July 2026 that AI "that has more direct impact on credit decisions affecting individual customers—presents more substantial legal compliance challenges than other AI use cases".11

The Treasury's 2024 report names the failure that matters most in a memo: generative AI "can be susceptible to 'AI hallucinations,' producing confidently stated but incorrect output".40 In a memo, a hallucination reads like any other sentence: a liquidity figure from the wrong statement, a ratio from an old spread, a mitigant no document supports. NIST's voluntary framework gives four functions a bank can evidence: GOVERN, MAP, MEASURE and MANAGE.41 Colorado's automated-decision law takes effect January 1, 2027 for covered consumer decisions; whether a business credit with personal guarantors touches it is a question for counsel.12

Why the software that drafts should not be what checks

Banks separate the person who prepares a credit from the person who approves it. The OCC's 2026 booklet says an "independent loan approval authority (such as a senior credit officer or credit risk management team) whose primary goal is credit quality can introduce more objectivity to the loan approval process".4 Research on language models finds the same limit in machines. A study presented at ICLR 2024 found that models "struggle to self-correct their responses without external feedback, and at times, their performance even degrades after self-correction".42 The study used reasoning tests, and the lesson carries over to memos. A check is worth having when it compares the draft with something the drafter did not write: the page, the spread, the policy.

Check against the page

Every figure cited

A number that cannot point to a document and page cannot go to review.

Check against the policy

Every limit tested

A separate test of coverage, leverage, loan to value, advance rates and liquidity, each with its section.

Check against the spread

Every dependant traced

A change to one figure lists everything built on it, and nothing becomes final until a person accepts it.

What the bank's people keep: conflicts, exceptions, the grade

  • Choosing between conflicting documents, and writing down why.
  • Accepting what goes in the memo, approving exceptions within authority, and setting the grade.
  • Verifying that documents are genuine. A citation shows where a figure came from.
  • Explaining a decline. Regulation B still requires specific reasons on request, which come from the analysis.17 The CFPB withdrew its circulars on adverse-action reasons from complex algorithms in May 2025; the rule itself did not change.43
  • The bank's responsibility for the credit, whoever drafted the memo.37
13 · How teams write memos today

How credit teams write memos today: who does what, and where three days go

In shortThe relationship manager brings the request, the analyst writes the memo from the spread and the file, the underwriting manager reviews it, and an approver or committee decides. Most of the analyst's days after the spread go to moving numbers and describing documents. The committee calendar turns a one-day slip into a week.

Who writes, reviews and approves a credit memo

RM

Relationship manager

Agrees the request and term sheet, chases the last documents, renegotiates when the borrower asks.

Cares about: whether the memo still makes Thursday.
CA

Credit analyst

Writes every section from the approved spread and the file, tests the structure against policy, drafts the grade rationale, rewrites when something changes.

Cares about: time for judgment instead of pasting.
UM

Underwriting manager

Reviews every memo before an approver sees it, sends questions back, checks figures against their sources.

Cares about: where each number came from.
CC

Chief credit officer and loan committee

Approve within authority, decide exceptions, set the final grade.

Cares about: every exception with its section and mitigant, on one page.
LR

Credit administration and loan review

Keep the template and the exception log, test memos after the fact, answer examiners.

Cares about: evidence an examiner can follow a year later.

Four people and three outside parties before committee

A memo passes through four people, and waits on three outside parties, before committee
  1. 1Request and term sheet

    Amounts, rates, terms, collateral.

    Relationship managerDay 0
  2. 2File complete, spread approved

    Statements, returns, appraisal review, field exam, personal statements.

    Analyst and reviewerDays to weeks
  3. 3Memo drafted

    Twelve sections from the spread and the file; policy tested; grade proposed.

    Credit analystAbout 3 days by hand
  4. 4Changes reworked

    Late K-1s, a repriced loan, a conflicting statement.

    Credit analystHours each
  5. 5Review

    Questions back, corrections, sign-off.

    Underwriting managerA day
  6. 6Decision

    Approval within authority, or the next committee meeting after the lock.

    Approver or committeeBy the calendar

Illustrative · replace with your own numbers · Times are illustrative for a middle-market credit. No public source measures them; time five of your own memos.

Show the numbers
StepWhat happensWhoTime
Request and term sheetAmounts, rates, terms, collateral.Relationship managerDay 0
File complete, spread approvedStatements, returns, appraisal review, field exam, personal statements.Analyst and reviewerDays to weeks
Memo draftedTwelve sections from the spread and the file; policy tested; grade proposed.Credit analystAbout 3 days by hand
Changes reworkedLate K-1s, a repriced loan, a conflicting statement.Credit analystHours each
ReviewQuestions back, corrections, sign-off.Underwriting managerA day
DecisionApproval within authority, or the next committee meeting after the lock.Approver or committeeBy the calendar

Where three days go after the spread is approved

Pasting and describing take half of a hand-written memo's three days

Working days after an approved spread, one middle-market memo (labels in days)

Pasting spread tablesDescribing borrower, guarantors, collateralTesting policyRisks, mitigants and gradeUpdates after changes, review questions
By hand, about 3 days0.750.750.50.50.5

Illustrative · replace with your own numbers · An estimate. No regulator or study publishes time per memo; one vendor writes that memo creation “may take another few days” after data entry.

Show the numbers
Pasting spread tablesDescribing borrower, guarantors, collateralTesting policyRisks, mitigants and gradeUpdates after changes, review questions
By hand, about 3 days0.750.750.50.50.5

The estimate above is ours, built from the sections and the vendor descriptions in section 11. One vendor article for community bankers puts it in words: lenders "manually create key documents like credit memos and annual loan reviews. The document creation process may take another few days."19 Its estimate of days spent on data entry rests, by its own footnote, on "anecdotal conversations" with lenders, which is the honest state of the evidence.

The committee calendar multiplies every slip

The OCC notes that committee approval can "reinforce the credit culture but can diminish accountability and can slow a bank's responsiveness", and that "The board generally reviews and approves any commercial loan large enough to adversely affect the bank's financial condition".4 Committees meet on fixed dates, and memos lock before them; the sample bank locks memos 24 hours ahead. A memo that misses Wednesday morning waits a week if the committee meets weekly. The FDIC found that "Nearly three in four banks have at most three levels of approval".36 The days go to the steps before approval.

Word template, outside analysis team or AI drafting

In house

A word-processor template and the spread workbook

Flexible and familiar. The weak points: pasted tables that stop matching the spread, text copied from last year's memo, and no link from a sentence to its page.

Outsourced

An analysis team elsewhere

An offshore or shared-service team drafts to the bank's template. It moves the hours; the bank still reviews every memo and keeps the responsibility.37

Software

Templates and AI drafting

Origination-system templates that merge fields, general writing assistants, and newer tools that read the file and draft with citations. They differ most on what happens after a change.

Part B · See it working

Botminds Credit Memo Automation, one $19 million memo from approved spread to loan committee

Part A described the work without naming a product. This part shows how Botminds does it, at a fictional community bank in Grand Rapids with a 12-section memo template. Every bank, borrower, person, number and document in the screens is sample data.

14 · One memo, start to finish

Drafting the Brennick memo: twelve cited sections, one late K-1 figure carried through, on the manager's desk by 10:12 a.m.

In shortThis is the example from the top of the page, inside the product. Hannah Okafor, the senior credit analyst, presses one button and six agents write all twelve sections with every number cited. She settles a conflict between two documents, types the late K-1 figure into the spread, watches the memo rewrite what depended on it, accepts the changes and sends the memo for review by 10:12 a.m.

1

Spread approved, file complete, twelve sections waiting

Hannah approved version 3 of the spread on Friday at 4:48 p.m., and two minutes later the deal file was marked complete. On Monday the memo opens in the bank's own template: the live spread on the left, each ratio shown against its policy limit, and the twelve sections as gray outlines on the right, waiting for the first draft.

The editable cells on the left are the four figures cash flow is built from: EBITDA, unfinanced capital spending, tax distributions and other distributions.

Ready to write. Spread version 3 with its four editable cells and each ratio against its minimum on the left; the empty template and the Write the memo button on the right.
2

Fourteen pages, every number underlined and cited

"Write the memo" fills the sections in order. The file reader indexes 1,906 figures with their pages, the spread and cash flow analyst computes coverage of 1.60x and 1.42x globally, and the memo writer drafts 14 pages with 113 numbers, each one cited in the margin.

The recommendation is written in the bank's own voice, two policy exceptions are found and mitigated, and grade 5, Acceptable, is proposed. The credit is above the chief credit officer's $15,000,000 authority, so it goes to committee.

The first draft. Section 1 with every figure underlined and its sources in the margin; above it, one conflict to resolve and the accountant's new letter.
3

Any number opens the page it came from

In the collateral table Hannah clicks the plant value. The appraisal of 2250 Ironwood Industrial Drive opens at page 2 of 86, with "Final value, as is, fee simple: $5,400,000" highlighted, the date the bank's appraisal desk reviewed it, and the three sections that cite it.

That value is why real estate loan to value is 77.8% against a 75% maximum: exception 1.

The page behind a value. The appraisal's summary page beside the collateral table, the value highlighted, the citing sections listed at the foot.
4

Two documents disagree, and nothing is used until she chooses

The checks found that Daniel Brennick's signed statement lists $1,920,000 of liquid assets while his brokerage statement of August 31 shows $1,410,000. The memo uses neither figure until Hannah decides. She takes the later, third-party figure and writes the reason; the choice goes on the change log.

With the verified figure, the guarantors hold $2,040,000 against the $1,900,000 the policy needs, so the test still passes, now on a figure that is true.

A conflict to resolve. Both documents side by side, the effect on the policy test, and the reason that goes on the record.
5

The K-1s arrive, one cell changes, the memo follows

At 9:05 a.m. the accountant's 2025 K-1s put tax distributions at $1,717,000. Hannah types the figure into spread row 55. Version 4 of the spread recomputes the deal and the memo rewrites what depended on it: 12 numbers updated and 3 paragraphs rewritten in 7 sections, a new exception for global coverage at 1.18x, and a new mitigant.

Every changed number shows its old value; every rewritten passage carries a blue rule and the note "Rewritten · spread v4". Nothing is final until she accepts.

One spread change, the memo rewritten. The old values struck through in the spread, the change summary with Undo and Accept all, and the rewritten recommendation marked in place.
6

Seven checks pass, and the memo goes for review

At 9:08 a.m. Hannah accepts the changes. The readiness list shows seven checks: 130 of 130 numbers cite a page, no open conflicts, the latest figures in the spread, every change accepted, every exception mitigated, a grade proposed with reasons, and conditions listed.

At 10:12 a.m. she sends it to Renee Dubois, the underwriting manager, due back by 5:00 p.m., on its way to Thursday's committee with three exceptions.

Sent for review. Seven readiness checks, the recommendation as the committee will read it, and the approval path with each person's role.
Of 1,906 figures in the file, the memo cites 130, and one late K-1 moved 12 of them

The Brennick memo, Monday, October 12

Figures indexed with their pages1,906
Numbers cited in the memo sent for review130
Numbers the K-1 change updated12

Fictional example from this guide · From the sample memo's run log and change log.

Show the numbers
StageCount
Figures indexed with their pages1,906
Numbers cited in the memo sent for review130
Numbers the K-1 change updated12

The solution's design target is a cited first draft the same day the spread is approved, with every number traceable to a page. Both are targets, to be measured on your own memos.

15 · Every screen

Twelve more screens of the memo desk, from drafting in place to the committee agenda and the bank's settings

In shortOne memo is the story. These screens show the rest: the memo being written, the new exception and mitigant the change produced, the rewritten cash flow section, last year's memo used as a source, structure against policy, the grade and its scorecard, the change log, the deal file, the pipeline of memos, the committee agenda and the bank's settings.

Written in place. The cash flow section fills in line by line, each figure underlined, with its sources listed in the margin beside it.
A new exception and its mitigant. Exception 3, global coverage 1.18x against 1.20x, marked "New · from spread v4" with its sources.
Risks and mitigants. One risk, one checkable mitigant, sources in the margin; the new risk sits at the top.
The cash flow section. The final tax distributions, cash available, each loan's debt service and the coverage the committee will read.
Last year's memo as a source. Carried-forward text cites the October 2024 memo at page 6, so the reviewer can check it against this year's file.
Structure and cash flow. Each loan's debt service, every policy limit as a bar, and the figures that depend on the change, before and after, with their sources.
Exceptions and grade. Each exception in the four-part form, and grade 5 proposed from a 5.05 scorecard, a reason beside every factor. The approver sets the grade.
The change log. Every edit with its time, the person's initials or the software's tag, and the value before and after, such as tax distributions from $1,050,000 to $1,717,000.
The deal file. 39 documents and 586 pages, every one read, with the numbers each supports in the memo and the conflicts resolved.
Memos in flight. Seven memos ordered by due date, each with its exceptions, its count of cited numbers and its stage.
Loan committee. Thursday's five credits with grade, exceptions and memo status; memos lock for editing 24 hours before the meeting.
Template and policy. The bank's sections, the citation and conflict rules, and the limits every memo is tested against, versioned with the policy revision.

Select any screen to open it larger. The bank, borrowers, people and figures are fictional. The screens are shown with US dates and spelling.

16 · Agents and who signs

Who drafts the memo, who checks it against the page, the policy and the spread, and who owns it

In shortEach agent has one job and limits it does not cross, and the drafting is checked by agents that compare it with something it did not write: the page, the policy, the spread. None of them accepts its own changes, waives an exception or sets a grade. The credit analyst owns the memo, the underwriting manager reviews it, and the chief credit officer or committee decides.

From file reader to consistency checker, six agents

File reader

Reads every document in the deal file, from audited statements and returns to appraisals, field exams and quotes, and indexes each figure with its page.

Never keys a number it cannot point to on a page.

Spread and cash flow analyst

Takes the approved spread and computes cash available, business and global coverage, leverage, pro forma debt service and the stress cases.

Never changes the spread the analyst approved.

Memo writer

Drafts each section in the bank's template from the spread, the file and the prior memo, with every number and claim cited.

Never writes a number or a mitigant without its source; says when it carries text forward.

Policy checker

Tests coverage, global coverage, leverage, loan to value, advance rates and guarantor liquidity against the policy, and lists each exception with its section, actual, limit and approver.

Never waives or approves an exception.

Risk grader

Scores the bank's scorecard and proposes a grade on its 1 to 9 scale, with the reason for each factor.

Never sets the final grade; the approver does.

Consistency checker

Keeps the memo in step with the spread: when a spread figure changes, it finds every dependent number and passage, has them recomputed, rewritten and tested against policy again, and marks each change.

Never accepts its own changes.

Who signs: the analyst, the reviewer and the approver

Owns the memoCredit analystResolves conflicts with a reason, edits any paragraph, accepts or undoes every change, sends the memo.
Reviews every memoUnderwriting managerOpens any number at its page, reads the change log with before and after, sends questions back.
DecidesChief credit officer or committeeApproves within authority, approves the exceptions, sets the final grade.

A memo with an uncited number cannot be sent for review. Agent steps and people's decisions are labeled apart on the change log, every version is kept for the credit file, and memos lock 24 hours before committee.

The analyst, reviewer, RM and CCO behind the Brennick memo

Fictional, from the sample data
HO

Hannah Okafor · senior commercial credit analyst

Seven memos in flight.

"The spread takes a day. The memo takes three, and most of it is pasting."
RD

Renee Dubois · underwriting manager

Reviews every memo before it goes to an approver.

"When I see 1.60x, I want to see where it came from, in one click."
TB

Tyler Brandt · relationship manager, middle-market banking

Negotiated the $19 million request; chases the last documents before committee.

"The CPA is sending the K-1s Monday. Can the memo still go Thursday?"
MA

Martin Asher · chief credit officer

Approves to $15 million and chairs loan committee above it.

"Every exception, its policy section and its mitigant, on one page."
17 · What goes in and out

What the memo desk reads from the approved spread and deal file, and the cited memo, grade and change log it leaves

In shortIt reads the documents your credit team already gathers, writes into your own template, tests against your own policy, and leaves a memo in which every number opens its page, plus the exceptions with their mitigants, the proposed grade with its reasons, and a record of every edit. Your origination system and your spreads stay where they are.

From the file

  • The approved spread and global cash flow
  • The request and term sheet
  • Audited statements, interims, business and personal returns, K-1s
  • Appraisals, field exams, quotes, personal and brokerage statements
  • The last approved memo for the borrower

From the bank

  • Your memo template and its sections
  • Your credit policy: limits, sections, approvers
  • Your scorecard and grade scale
  • Your stress cases and approval authority
Agents read, compute, draft and check Every section in your template, every limit in your policy, every change traced
The analyst accepts every change
Every number cites its page

Outputs

  • The draft memo in your format, every number cited
  • Policy exceptions with section, actual, limit, mitigant and approver
  • Key risks with checkable mitigants
  • A proposed risk grade with a reason per factor
  • A change log with before and after, and every version

What changes for the team

  • Drafts to read and edit, written the day the spread is approved
  • Late documents handled as changes to accept
  • Reviews that start from the page behind each number
Pasting and describing are the hours the solution is built to take

Days per middle-market memo after the spread is approved, by step

By hand (estimate)With the solution (estimate)
Pasting spread tables0.75 days0.05 days
Describing borrower, guarantors, collateral0.75 days0.1 days
Testing against policy0.5 days0.05 days
Risks, mitigants and grade rationale0.5 days0.1 days
Updating numbers after a change0.25 days0.02 days
Review and questions back0.25 days0.2 days

Illustrative · replace with your own numbers · Estimates published with the solution. Its design target is a cited first draft the same day the spread is approved; measure both on your own memos.

Show the numbers
By hand (estimate)With the solution (estimate)
Pasting spread tables0.75 days0.05 days
Describing borrower, guarantors, collateral0.75 days0.1 days
Testing against policy0.5 days0.05 days
Risks, mitigants and grade rationale0.5 days0.1 days
Updating numbers after a change0.25 days0.02 days
Review and questions back0.25 days0.2 days

Origination system, spread versions and prior memos to connect

Loan origination systemThe request, the decision, the memo of record
Spreading tool or workbookThe approved spread and its versions
Document managementThe deal file, prior memos
Borrower portalStatements and returns in, requests out
Core bankingExisting exposure and deposits
Appraisal managementValues and review dates
Identity and accessAuthority limits, separation of duties
Committee toolsThe agenda, the pack, the minutes

For each, check whether it has an API, a file feed, or only screens, and who owns it.

Your memo template, spreads and committee keep their shape

Your memo template

Kept as it is: sections, order and voice are settings. Changes are versioned.

Your spreads

The memo is written from the version the analyst approved, and names that version beside every ratio.

Your credit policy

Becomes limits with section numbers, approvers and the stress cases you run.

Your origination system

Stays the system of record; the accepted memo goes into it through your normal process.

Your loan review

Gets memos it can test number by number, with every edit's author and reason.

Your committee

Reads the same memo, locked before the meeting, with every exception on one page.

Part C · Are you ready to automate?

The business case for automated credit memo drafting

You write commercial credit memos, manage the people who do, or answer for the credits they support. This part is written for you: what slow and stale memos cost today, what automating the drafting could return, whether your team is ready, and what to ask any vendor of credit memo software, including us.

18 · What slow memos cost

What a hand-written memo costs you in analyst days, missed committee dates and numbers nobody updated

In shortStart from your own costs. No regulator or study publishes the hours a memo takes or how often memos carry a stale figure, so the numbers that matter are yours. A few published figures frame them: what an analyst hour costs, how often commercial loans go bad, and how fast other banks decide.

$57/hr

a credit analyst's median pay, $83,510 a year, loaded for benefits at the 70% wage share of employer costs. At three days a memo, that is about $1,370 of analyst time before review.34,35

BLS, May 2025 wages and June 2026 compensation costs · our arithmetic
1.25%

of community banks' commercial and industrial loans were noncurrent at June 30, 2026, against 0.96% across all insured institutions.44

FDIC Quarterly Banking Profile, Q2 2026
3 in 4

banks approve their typical small business loan within ten business days. Three days of drafting uses much of that window.36

FDIC Small Business Lending Survey, 2022
Three days a memo becomes years of analyst time at a busy bank

Analyst working days a year spent drafting memos at three days each, by memos a year

100 memos a year300 days
200 memos a year600 days
300 memos a yearabout four analysts' working years900 days
500 memos a year1,500 days

Illustrative · replace with your own numbers · Illustrative: three working days per memo after the spread, about 230 working days per analyst a year. Count renewals and annual reviews as memos.

Show the numbers
VolumeAnalyst days
100 memos a year300 days
200 memos a year600 days
300 memos a year900 days
500 memos a year1,500 days
What nobody publishes. There is no public figure for hours per memo, memos per analyst per week, the share of memos with a stale or untraceable number, the share of credits that miss a committee date because of the memo, or the share of grades an examiner would change. Vendor figures for these come without a dataset. Measure your own.

Timing five memos section by section

CostWhere it hidesHow to find your number in a week
Drafting timePasting tables, describing documents, testing limitsTime five memos from approved spread to sent for review, by section
Rework after changesLate K-1s, repricing, a revised appraisalCount changes after drafting on the last 20 memos, and the hours each took
Review timeThe reviewer re-checking figures against the spread and fileAsk two reviewers to log minutes and questions sent back for a week
Stale numbersSummaries that disagree with the bodyRe-check every figure in ten recent memos against the final spread
Missed committee datesMemos that missed the lockFrom committee minutes: credits deferred a meeting, and why
FindingsUnidentified exceptions, weak analysis, unsupported gradesYour last two exam reports and loan review findings on approval documentation

Stale ratios approved and borrowers who could not wait

The credit approved on a stale ratioOne number that never updated, on one large credit, can outweigh a year of analyst time.
The borrower who could not wait a weekA memo that misses Wednesday's lock waits for next Thursday, and so does the borrower's machine order.
The grade that understated riskExaminers are "most concerned when rating inaccuracies understate risk".3
The exception nobody identifiedFound by loan review or an examiner after funding, with no mitigant written.4
Your best analysts' afternoonsSpent pasting tables instead of reading contracts, customers and margins.
19 · Your return

Analyst hours per memo before and after: a credit memo return calculator

In shortPut in your own numbers. The calculator starts from a published analyst wage and asks you for the rest: how many memos you write, the hours they take now, the hours you expect after, and what the tool and your testing cost a year. Every default marked illustrative or estimate is an assumption to replace.

Edit instead of paste, and late changes traced

Drafting time

Read and edit instead of paste

Sections arrive written in your template, each number cited; the analyst edits and decides.

memos × hours saved × loaded hourly cost
Late changes

A change traced, then accepted

A late figure rewrites what depends on it, marked for acceptance, instead of a search through every page.

changes after drafting × hours each × hourly cost
Review

Checking by clicking

The reviewer opens any number at its page and reads every edit with before and after.

memos reviewed × minutes saved ÷ 60 × hourly cost
Accuracy

Stale numbers caught

Every dependant of a changed figure is listed, so the summary cannot keep an old ratio.

stale figures per memo, before and after, by planted change
Speed

Committee dates kept

A draft the day the spread is approved leaves room for the late document before the lock.

credits deferred a meeting, before and after
Exams

Evidence ready to hand

Exceptions in the four-part form, grade reasons per factor, every edit on record.

findings on approval documentation, before and after

Your memo volume, drafting hours and late-change rework

Only the hourly cost is built from published figures: the BLS median wage for credit analysts, $83,510, divided by 2,080 hours and by the 70% wage share of employer costs.34,35 Every input marked illustrative or estimate is an assumption.

Your volume
Hours per memo after the spread
Your cost
Illustrative yearly value
Memo drafting time today, valued$0
Analyst time released, valued$0
After your yearly cost$0
Analyst hours released a year0
Memos a year to cover your cost0

Formulas, per year:
Drafting time today = memos × hours today × hourly cost
Time released = memos × (hours today − hours with automation) × hourly cost
After your cost = time released − yearly cost
Break-even memos = yearly cost ÷ (hours saved × hourly cost); a very large number means the hours saved never cover the cost

The 24 hours today is three working days, the estimate used in section 13; the 4 hours with automation is the solution's own estimate of about half a day, mostly review. Not counted: late-change rework, reviewer time, committee dates kept, stale numbers caught and exam evidence. Released hours are value only when you decide what they are for: more relationships per analyst, faster answers, or deeper analysis.

The hours saved per memo decide how many memos pay for the tool

Memos a year to cover $100,000 of yearly cost, at $57 an analyst hour

Saves 20 hours a memo88 memos
Saves 12 hours a memo146 memos
Saves 6 hours a memo292 memos

Illustrative · replace with your own numbers

Show the numbers
Hours savedMemos a year
Saves 20 hours a memo88 memos
Saves 12 hours a memo146 memos
Saves 6 hours a memo292 memos

A bank that writes 300 commercial memos a year, renewals included, is above every one of these lines. A bank that writes 40 short memos for simple renewals probably is not, and should weigh that before buying anything.

Start here20 · Readiness check

Credit memo readiness check: volume, template, policy, error history, the deal file and governance, scored 0 to 16

In shortPick the answer closest to your team today. Eight questions score 0 to 2; the last is for reflection. The meter adds up your score as you go, and each question says why it matters and what a strong answer sounds like.

1
Volume

How many commercial memos, new credits, renewals and modifications together, does your team write in a year?

Why it mattersVolume turns hours per memo into analyst capacity, and renewals are memos too.
A strong answer"About 300, two-thirds renewals, most of them owner-managed businesses with guarantors."
2
One template

Is there one memo template, owned and versioned, that every analyst follows?

Why it mattersSoftware writes into a template. If each analyst keeps a variant, settle that first.
A strong answer"One template, owned by credit administration, with a global cash flow section and a renewal history section."
3
Policy as numbers

Does your credit policy state its limits as numbers with section references and named approvers?

Why it mattersA limit has to be a number to be tested on every memo, and an exception needs a section and an approver.13
A strong answer"Coverage 1.25x and 1.20x global in section 4.2, loan to value 75% in 5.1, with an authority matrix."
4
Your baseline

Do you know your hours per memo, your changes after drafting, and how often a memo misses its committee?

Why it mattersNo public benchmark exists for any of them, so your own baseline is the only way to prove an improvement.
A strong answer"About 20 hours a memo, one late change on most of them, and three deferrals last quarter."
5
Approved spreads

Is the spread approved, with a version, before the memo starts?

Why it mattersA memo written from a spread still being edited has no fixed source for its numbers.
A strong answer"Yes, the spread is signed and versioned, and the memo names the version."
6
Findings

Have examiners, loan review or audit commented on approval documentation, exceptions or grades in the last two years?

Why it mattersFindings bring deadlines and budgets. The OCC lists inadequate financial analysis among underwriting weaknesses.4
A strong answer"Loan review found three exceptions with no written mitigant and two grades without reasons."
7
Owner and budget

Is there a named owner of the memo process with a budget to change it?

Why it mattersMemos cross credit analysis, underwriting, relationship managers, credit administration, loan review and IT. Without one owner it stalls.
A strong answer"Our chief credit officer sponsors it, and analyst hiring budget can move."
8
Governance

Do you have a path to approve AI in credit work: vendor due diligence, a view under SR 26-2, human acceptance of every change and an audit trail?

Why it mattersThe 2026 model guidance leaves generative AI to your own framework, and third-party guidance keeps the responsibility with you.10,37
A strong answer"Vendor management and model risk have a path for AI tools, and every memo has a named owner who accepts changes."
9
Vision · for reflection

If an examiner picked one of last quarter's memos tomorrow and asked where its coverage ratio came from, and what changed after the draft, what would have to be true for you to answer in a minute?

Why it mattersYour answer lists the gaps. Each gap is a candidate job for software: citing, tracing, testing or logging.
A strong answerA short, specific list, for example: "every number cited to a page, the spread version named, every change logged with before and after, and exceptions in one place."

Write policy limits as numbers before drafting memos

0–6

Explore

Build the baseline first: time five memos, count changes after drafting, settle one template and write your limits as numbers with sections. Start narrow, for example with citations and limit tests on renewals.

7–11

Ready to pilot

Run a measured pilot on 10 to 20 of your own approved credits, with one planted change each. Compare drafting hours, stale numbers and reviewer questions with your current process, and keep your analysts accepting every change.

12–16

Ready to implement

Plan the full desk: your template and policy as settings, authority limits, the origination system and document links, committee packs, loan review access and the evidence an examiner will ask for.

21 · Questions for any vendor

Testing a credit memo vendor: traceable numbers, late deal changes, conflicting documents, and the answers that should worry you

In shortAsk every vendor the same questions, us included. The answers show how the memo is built: what it reads, whether every number can be traced, what happens when the deal changes or two documents disagree, whose template and policy apply, and how you would measure it on your own files.

AskA good answerA warning sign
What it reads and cites
Does it read the whole deal file, or only fields already in our origination system?The documents themselves, each figure indexed with its pageA mail merge of system fields
Can every number in the draft be opened at its document and page?Yes, for the analyst, the reviewer and the examinerA confidence score in place of a page
Can a memo with an uncited number be sent for review?No; the count is shown before sending"The analyst checks it"
When the deal changes
When one spread figure changes, what happens to the memo?Every dependent number and passage is updated and marked for acceptance"Regenerate the memo"
Do edits the analyst made survive the change?Yes; only dependent passages are rewritten, and locked sections are left aloneA new draft that loses the analyst's edits
Does the policy test re-run after a change?Yes, and a new exception appears with a drafted mitigant to acceptLimits tested once, at first draft
Conflicts and judgment
What does it do when two documents disagree?Shows both and uses neither until a person chooses, with a reason loggedUses the first figure it read
Can it approve an exception or set the grade?No; it proposes, with reasons, and a named approver decidesGrades written as final
How does it mark text carried from last year's memo?Cited to the prior memo and page, switchable by the bankCopied silently
Your template and policy
Does it write into our template, or ask us to adopt its own?Ours, section for sectionA fixed layout with our logo
Who can change limits, approvers and stress cases, and is it versioned?The policy owner; versioned with the policy revisionSettings any user can change
Does the memo name the spread version behind every ratio?Yes, and it uses only the approved versionReads the latest spread, whatever its state
Your data and AI
Which AI models do you use, where do they run, and does our data train them?Named models, a region you choose, no training on your data, in writing"Proprietary AI", no more detail
How should we classify each part under SR 26-2 and our third-party program?A part-by-part answer for your model risk team"It's all a model" or "none of it is"
Is drafting checked by something other than the drafter?Checks against the page, the policy and the spread, kept separate"The model reviews its own output"
Proof
Can we test it on our own approved credits, with a change we choose, before we sign?Yes, with our analyst's memo as the answer keyDemo files only
What will you report from the test?Uncited numbers, numbers that should have moved and did not, missed exceptions, changes made final without a person, analyst hoursOne accuracy percentage
Who sends the memo?Your analyst, after accepting every changeMemos sent automatically

We found no published independent test of any credit memo tool's accuracy, as of October 2026. A test on your own approved credits, with one planted change each, is the fairest comparison, and the same test measures your current process.

22 · How to start

Redrafting approved credits with planted changes: a ten-week memo trial your chief credit officer can sign off

In shortMeasure first, then redraft recent approved credits with a planted change in each, then run alongside live memos, then decide with four counts. None of these steps commits you to a vendor.

  1. Time five memos, from approved spread to sent for review, and count the changes after drafting on the last twenty.
  2. Gather 10 to 20 approved credits with their spreads, files and final memos, including a renewal, a credit with exceptions, a guarantor conflict and a late document.
  3. Redraft each, then change one figure with long dependencies, such as tax distributions or a guarantor's liquidity, and count what moved.
  4. Run alongside live memos for four weeks, with your analysts accepting every change and your reviewers logging questions.
  5. Decide with four counts: uncited numbers, numbers that should have moved and did not, exceptions missed, and analyst hours to a memo ready for review.
A ten-week pilot ends with a decision on four counts
Your teamVendor
Time five memos; count late changes
Choose 10 to 20 approved credits
Load your template, policy and scorecard
Redraft the test set; plant one change each
Run alongside live memos
Score the four counts and hours
Decide
Week 0246810

Illustrative · replace with your own numbers

Show the numbers
ActivityFromTo
Time five memos; count late changes02
Choose 10 to 20 approved credits13
Load your template, policy and scorecard14
Redraft the test set; plant one change each35
Run alongside live memos59
Score the four counts and hours89.5
Decide9.510

Uncited numbers and missed dependants after a planted change

MeasureHowWhy
Uncited numbersNumbers in the draft without a document and pageShould be zero; it is the first control
Missed dependantsAfter the planted change, numbers that should have moved and did not, against your analyst's recalculationThe failure that reaches committee
Missed exceptionsLimits broken in the final memo that the draft did not listUnidentified exceptions are an exam finding4
Changes made final without a personFrom the change logShould be zero
Analyst hours and reviewer questionsStopwatch from approved spread to sent; questions sent backThe cost case rests on them
Judgment rewritesEvery place the analyst rewrote a conclusion, and whyShows where the tool's limits are
The full working-session questions: 21 questions in seven groups

Bring credit analysis, underwriting, relationship managers, credit administration, loan review, model risk, vendor management and IT into one room. Each question says why it matters, what a strong answer looks like, and the warning sign.

A

Memos a year, short forms and approvers by size

A1

How many memos do we write a year, split by new credits, renewals and modifications, and by size?

Why it mattersRenewals are where history and carried text matter most.
Strong answer · warning sign
Counts by type and size.
One number, nobody sure of the mix.
A2

Which credits would we keep on a short form, and why?

Why it mattersAnalysis should be "commensurate with the level of risk".3
Strong answer · warning sign
A written short-form rule.
"Everything, full length."
A3

Who owns the memo, who reviews, and who approves at each size?

Why it mattersAuthority limits become settings.
Strong answer · warning sign
An authority matrix.
"It depends who's in."
B

Memo template sections, limits and a written scorecard

B1

Is there one template, and does it have sections for global cash flow, renewal history and grade reasons?

Why it mattersA section the template lacks will be missing from every draft.
Strong answer · warning sign
One template with those sections.
Each analyst's own layout.
B2

Do we test against policy's outer limits or our inner targets?

Why it mattersThe OCC notes policies "often include outer limits" with "inner targets".4
Strong answer · warning sign
A stated choice.
Different by analyst.
B3

Is our scorecard written down, with weights and factor definitions?

Why it mattersA grade can carry reasons only if the factors are defined.20
Strong answer · warning sign
A versioned scorecard.
Grades by feel.
C

Figures off the final spread and deferred committee dates

C1

What did loan review or examiners say about approval documentation in the last two years?

Why it mattersFindings show where the process breaks.
Strong answer · warning sign
A list by type.
Nobody tracks them.
C2

Re-check every figure in five recent memos against the final spread: how many differ?

Why it mattersThe cheapest way to size the stale-number problem.
Strong answer · warning sign
Done, with differences explained.
"Our memos are fine."
C3

How many credits were deferred a committee meeting last year because a memo was late?

Why it mattersThat is the borrower's cost of the memo.
Strong answer · warning sign
A count from the minutes.
Unknown.
D

Late documents, conflicting sources and appraisal dates

D1

Which documents most often arrive after drafting starts?

Why it mattersThose are the changes the tool must trace.
Strong answer · warning sign
K-1s, appraisal reviews, repricing.
"Everything arrives on time."
D2

What is our rule when two documents disagree?

Why it mattersIt becomes a setting.
Strong answer · warning sign
Written, with who decides.
Habit.
D3

Do we record the appraisal review date beside the value?

Why it mattersReview comes before the final decision.6
Strong answer · warning sign
Always.
Value only.
E

Where accepted memos, spreads and prior memos live

E1

Where does the accepted memo need to go, and in what form?

Why it mattersSets the integration work.
Strong answer · warning sign
The origination system and committee pack, named.
Unknown.
E2

Where do approved spreads and their versions live?

Why it mattersThe memo must name the version it used.
Strong answer · warning sign
One place, versioned.
Analysts' drives.
E3

Where are prior memos kept, and can they be cited by page?

Why it mattersRenewals depend on them.
Strong answer · warning sign
One folder per relationship.
Email attachments.
F

Model risk, vendor review and a memo pilot sponsor

F1

Has our model risk policy moved from SR 11-7 to SR 26-2?

Why it mattersThe old letter was replaced on April 17, 2026.10
Strong answer · warning sign
Updated, with a view on AI tools.
Still cites SR 11-7.
F2

What does vendor management need before a pilot sees real borrower files?

Why it mattersDue diligence stays with the bank.37
Strong answer · warning sign
A known path and timeline.
First time anyone has asked.
F3

Who sponsors the change, and what budget can move?

Why it mattersA pilot without a sponsor ends as a demonstration.
Strong answer · warning sign
A named executive.
No sponsor.
G

Memos drafted the day the spread is approved

G1

What if every memo were drafted the day its spread was approved?

Why it mattersTests the appetite for a same-day standard.
Strong answer · warning sign
"Our analysts would work the credit."
"The committee calendar is the bottleneck anyway."
G2

What if every number in every memo opened at its page?

Why it mattersLinks drafting to review and exams.
Strong answer · warning sign
Loan review would test more files.
Nobody would look.
G3

Which steps would we never let software do without a person?

Why it mattersTells you where the decisions belong.
Strong answer · warning sign
Choosing between documents, accepting changes, exceptions, the grade.
"All of it": then start with citations and limit tests.
23 · Frequently asked questions

Credit memo questions people search: templates, length, policy exceptions, coverage ratios and AI drafting

In shortThe questions credit teams and buyers search for most, each answered on its own.

What is a credit memo in commercial lending?

A credit memo, or credit memorandum, is the written case a bank makes before lending to a business: the request, the borrower, the financial analysis, cash flow and coverage, collateral, guarantors, structure, policy exceptions, risks and mitigants, a proposed risk grade and the conditions of approval. An analyst writes it from the spread and the deal file, and an approver or loan committee decides on it. In accounting software the same words mean a note that reduces what a customer owes, which is a different thing.

How do you write a commercial credit memo?

Write one section for each question an approver asks, in the order they ask it, and build every section from named documents: request, borrower and management, industry, financial analysis, cash flow and debt service, collateral, guarantors, structure, exceptions, risks and mitigants, grade and conditions. Explain the numbers instead of restating the spread, and end each paragraph on what it means for repayment. Write the recommendation last, from the finished sections, and put it first.

What should be included in a credit memo?

At minimum, the purpose and source of repayment, the borrower's ability to repay, the guarantors, the collateral and its value, and the borrower's character, which federal safety-and-soundness standards ask a bank to consider before committing. Examiners also look for prior transactions and performance, key risks with mitigants, every policy exception with its reason, and support for the risk grade. SBA lenders follow the list in SOP 50 10 8.1.

Is there a standard credit memo template?

No regulator publishes one. The SBA lists what a 7(a) memo must address and lets lenders on its 7(a) Small and Express loans use their own internal credit memoranda, and the OCC sets four tests for the approval package. The section order, voice and length are each bank's own, which is why a memo tool should write into your template.

How long should a commercial credit memo be?

As long as the risk needs: the OCC says the level of analysis should be commensurate with the level of risk. A clean renewal can be a few pages; a $19 million credit with three policy exceptions can run to 14 or more. Length that comes from pasted tables adds nothing for the approver.

How long does it take to write a credit memo?

No regulator or study publishes a figure. One vendor describes a few days after the financial data entry, and one vendor case puts a corporate credit report at 20 hours by hand. Time five of your own memos from approved spread to sent for review to get a baseline you can defend.

How do you document a policy exception in a credit memo?

Give each exception four things in one place: the limit and its policy section, the actual against the limit with the source of each figure, a mitigant the bank can check or enforce with its source, and who approves it. The Federal Reserve's manual asks that the reason be detailed in writing and approved by a designated authority. The OCC expects pricing to pay for the extra risk, and never to serve as the mitigant.

What is a good debt service coverage ratio for a commercial loan?

No regulation sets one for conventional loans; each bank's credit policy sets its own minimum, sometimes with a separate global minimum (the example bank in this guide asks 1.25x on the business and 1.20x globally). For standard SBA 7(a) loans, SOP 50 10 8.1 sets 1.15 on the business and 1 to 1 on a global basis; 7(a) Small loans use 1.10, and changes of ownership follow their own appendix. A useful reading is the cushion in dollars: how much cash flow can fall before the minimum is crossed, tested with a stress case.

Why do tax distributions affect debt service coverage?

Because they leave the business before lenders are paid. An S corporation or partnership usually sends cash to its owners to pay their tax on the company's profit, so many banks subtract it from cash available for debt service, and the SBA asks lenders to justify the adjustment. The final figure often arrives late with the accountant's K-1s and can move every ratio in the memo.

What do examiners look for in a credit memo?

Whether the documentation and analysis were enough for an informed decision and the approver had the authority, in the OCC's 2026 words. They test four things in the approval package: analysis of the borrowers' and guarantors' repayment sources, prior transactions and performance, key risks and mitigants, and support for the approval, risk rating and accrual treatment. They also compare the bank's grade with their own.

Can AI write a credit memo?

It can draft one, section by section, from the spread and the file, if every number and claim is tied to its page and checked by something other than the drafter: the source page, the policy and the spread. Choosing between conflicting documents, approving exceptions, setting the grade and approving the credit stay with people who have authority under the bank's policy. Test any tool on your own approved credits with a planted change.

Is AI credit memo software a model under SR 26-2?

Mostly not. SR 26-2, issued April 17, 2026 to replace SR 11-7, excludes spreadsheet arithmetic and deterministic rule-based software from its definition of a model and places generative AI outside its scope. A statistical scorecard behind the grade may still be a model, and the rest is governed by third-party guidance and the bank's own AI policy.

What happens to a credit memo when the deal changes after drafting?

Every figure built on the changed one must be recalculated everywhere it appears, including the summary, and any judgment it supported must be rewritten. A change can also cross a policy limit and create a new exception that needs a mitigant and an approver. Done by hand, that means searching the whole memo; a good tool lists each dependant and marks it for acceptance.

What is the difference between a credit memo and a credit approval memo?

Banks use the terms loosely. Usually the credit memo is the analyst's full analysis and recommendation, and the approval memo or approval sheet is the shorter page the approver signs, recording the decision, the conditions and the exceptions approved. Many banks put both in one document with the approval page at the front.

24 · One-page summary

The commercial credit memo at a glance: the method, the October 2026 rules, readiness bands and terms

Print this page

In shortThe whole guide on one screen: the method, the rules as of October 2026, the readiness bands and the terms.

The method
  1. Start from an approved, versioned spread and a complete file; record the appraisal review date.
  2. Write one section per approver question, each from named documents; cite every number.
  3. Show cash available, coverage, global coverage and a stress case; name the spread version beside each ratio.
  4. Give each exception its section, actual, mitigant and approver; keep price out of the mitigants.
  5. Propose the grade with a reason per factor; carry renewal history and last year's projections.
  6. When a figure changes, update every dependant, re-test the policy, and log the change; then write section 1.

Readiness: score 0–2 on eight questions: 0–6 explore · 7–11 pilot · 12–16 implement.

As of October 2026: OCC lending booklet Version 1.0, July 2026 · SR 26-2 replaced SR 11-7 on April 17, 2026 · OCC and FDIC withdrew the 2013 leveraged lending guidance on December 5, 2025 · SBA SOP 50 10 8.1 in force from October 1, 2026.

14 terms
Credit memo
The written case for a loan, read by the approver and later by examiners.
Spread
The bank's grid of the borrower's figures; the memo's arithmetic.
Cash available for debt service
EBITDA less the cash the bank treats as unavailable.
DSCR
Debt service coverage: cash available ÷ loan payments due.
Global coverage
Borrower and guarantors together, against all their obligations.
Pro forma debt service
Payments on existing debt plus the loans being approved.
Stress case
Coverage recomputed for a bad year, such as EBITDA 20% lower.
Tax distributions
Cash a pass-through company pays owners for their tax on its profit.
Policy exception
A break from a credit policy limit, with a reason and an approver.
Mitigant
A fact or term the bank can check or enforce that offsets a risk.
Loan to value
Loan ÷ appraised value of the property.
Advance rate
The share of receivables or inventory a line lends against.
Risk grade
The bank's rating of the credit; the weak end maps to special mention, substandard, doubtful and loss.
Committee lock
The time before a meeting after which a memo cannot change.
25 · Sources

Sources

Accessed October 2026. Regulatory status statements are as of October 2026.

  1. eCFR, 12 CFR Part 30, Appendix A, Interagency Guidelines Establishing Standards for Safety and Soundness. ecfr.gov
  2. SBA, SOP 50 10 8.1 (Technical Policy Updates), effective October 1, 2026. sba.gov
  3. OCC, Comptroller's Handbook, Rating Credit Risk (April 2001, updated 2017 and March 2025). occ.gov
  4. OCC, Comptroller's Handbook, Lending and Loan Portfolio Risk Management, Version 1.0, July 2026. occ.gov
  5. Liberti and Petersen, "Information: Hard and Soft", NBER Working Paper 25075, 2018. nber.org
  6. Interagency Appraisal and Evaluation Guidelines, 75 FR 77450, December 10, 2010. federalregister.gov
  7. Policy Statement on Prudent Commercial Real Estate Loan Accommodations and Workouts, 88 FR 43115, July 6, 2023. federalregister.gov
  8. OCC and FDIC, NR 2025-119, withdrawal from the Interagency Leveraged Lending Guidance, December 5, 2025. occ.gov
  9. FDIC, Federal Reserve and OCC, NR 2026-2, Agencies Issue 2025 Shared National Credit Program Report, January 12, 2026. occ.gov
  10. Federal Reserve, SR 26-2, Revised Guidance on Model Risk Management, April 17, 2026. federalreserve.gov
  11. M. W. Bowman, "Responsible Innovation and Financial Inclusion", July 14, 2026. federalreserve.gov
  12. Colorado General Assembly, SB26-189, Automated Decision-Making Technology, signed May 14, 2026. leg.colorado.gov
  13. Federal Reserve, Commercial Bank Examination Manual (§2010.1, §2040.1). federalreserve.gov
  14. eCFR, 12 CFR Part 34, Subpart D, Appendix A, Interagency Guidelines for Real Estate Lending Policies. ecfr.gov
  15. OCC Bulletin 2026-13, Model Risk Management: Revised Guidance, April 17, 2026. occ.gov
  16. eCFR, 12 CFR 723.4, Commercial loan policy (NCUA). ecfr.gov
  17. eCFR, 12 CFR 1002.9 (Regulation B). ecfr.gov
  18. Federal Reserve Banks, Small Business Credit Survey, 2026 Report on Employer Firms. fedsmallbusiness.org
  19. D. Eads (Vine Financial), "Ensuring Commercial Lending Stability at U.S. Community Banks in 2025", CBA of Georgia newsletter, July 2025. assets-002.noviams.com
  20. Treacy and Carey, "Credit Risk Rating at Large U.S. Banks", Federal Reserve Bulletin, November 1998. federalreserve.gov
  21. Roberts, "The Role of Dynamic Renegotiation and Asymmetric Information in Financial Contracting", NBER Working Paper 20484, 2014. nber.org
  22. Chodorow-Reich, Darmouni, Luck and Plosser, "Bank Liquidity Provision across the Firm Size Distribution", NBER Working Paper 27945. nber.org
  23. FDIC, RMS Manual of Examination Policies, Section 3.2 Loans. fdic.gov
  24. FDIC OIG, Material Loss Review of First NBC Bank, New Orleans, Louisiana (AUD-18-002), 2017. fdicoig.gov
  25. Treasury OIG, Failed Bank Limited Review, First National Bank of Lindsay (OIG-25-024), 2025. oig.treasury.gov
  26. Treasury OIG, Failed Bank Limited Review, Santa Anna National Bank (OIG-26-023), March 11, 2026. oig.treasury.gov
  27. FRED, Commercial and Industrial Loans, All Commercial Banks (BUSLOANS), from Federal Reserve H.8, through September 2026. fred.stlouisfed.org
  28. Federal Reserve, Senior Loan Officer Opinion Survey, via FRED (DRTSCILM, DRSDCILM), through the July 2026 survey. fred.stlouisfed.org
  29. M. E. Biery (Abrigo), lending survey of nearly 250 lenders and analysts, February–March 2021, as published in a state bankers' newsletter, 2021. thenewslinkgroup.org
  30. Moody's, Automated credit memo (vendor page, case figures). moodys.com
  31. nCino, "Commercial relationship reviews in two days" (blog), September 10, 2026. ncino.com
  32. Evalueserve, "Global bank uses AI agents to automate credit memo creation" (blog). evalueserve.com
  33. S&P Global Market Intelligence, "S&P Global Launches Agentic AI-Powered Credit Memo Builder", June 4, 2026. press.spglobal.com
  34. BLS, OEWS May 2025, Credit Analysts (13-2041). bls.gov
  35. BLS, Employer Costs for Employee Compensation, June 2026. bls.gov
  36. FDIC, Small Business Lending Survey, executive summary (2022 survey, published 2024). fdic.gov
  37. Interagency Guidance on Third-Party Relationships: Risk Management, 88 FR 37920, June 9, 2023. federalregister.gov
  38. OCC Bulletin 2026-46, Third-Party Risk Management: Proposed Guidance and Request for Comment, September 11, 2026. occ.gov
  39. OCC, Semiannual Risk Perspective, Spring 2026. occ.gov
  40. U.S. Treasury, Artificial Intelligence in Financial Services, December 2024. home.treasury.gov
  41. NIST, AI Risk Management Framework 1.0, January 2023. nvlpubs.nist.gov
  42. Huang et al., "Large Language Models Cannot Self-Correct Reasoning Yet", ICLR 2024. arxiv.org
  43. Morgan Lewis, CFPB Guidance Tracker: Rescinded and Remaining (May 12, 2025 withdrawals). morganlewis.com
  44. FDIC, Quarterly Banking Profile, Second Quarter 2026. fdic.gov
Next step

See it on your own approved spreads and deal files.

Explore the solution, or bring one recently approved credit, its spread, its file and the memo your analyst wrote, and we will draft it with you, change one figure, and count what moved.

botminds.ai The complete guide to the commercial credit memo · October 2026. Halvern Bank & Trust, Brennick Precision Components, every other bank, borrower and firm, every person and every figure in the example and the screens are fictional. Regulatory status is as of October 2026; check the sources before relying on it.