Review proposed loan transfers and pledges

When to run this process

Trigger. Covered owner plans/intends/agrees to a source-defined Disposition, requests consent to nonpublic/additional descriptions, or corrects a previously objected proposal. Accountable owner. Servicing loan-owner disposition authority, functional reference allocation. Accepted output. Documented prohibited/nonprohibited/held proposed-disposition status and source-required notices, description consent when actually required, and continuation-agreement conditions. No completed sale/pledge/successor is implied.

Release or hold. Keep prohibited/incomplete proposals held or notice delivered as actually required. Do not invent an affirmative Servicer approval requirement for every disposition or treat silence as universal legal approval. A permitted proposal still needs actual owner transaction and any other applicable authority before records, cash or service rights change. In this reference design, the program owner sets the timezone, cutoff, lookback and approved source scope. Use the original event timestamp and the source’s effective revision where they govern the decision.

Use the process for U.S. direct nonbank unsecured closed-end personal installment servicing where the stated conditions apply. Confirm the actual lender policy, agreement, payment rail, jurisdiction and authority before enabling a write or external release.

Validate the result independently

Human pitfall. Missing/wrong owner or proposal, premature contact, unverified actual receipt. AI or agent pitfall. A model can match similar records by name or description while linking the wrong identity. Require the source key and its corroborating record.

Deciding evidence. Validate the exact proposal type before recording its decision. A pledge proposal does not create a servicing transfer or change custody by itself. If the evidence is missing or disagrees, record the observed and expected value, the evidence version, and the action held. Route the exception to Servicing loan-owner disposition authority, functional reference allocation and use the task owner below for correction.

Tasks and acceptance checks

• Accept proposal notice and establish disposition scope
• Determine prohibited status and give source-required objection
• Decide consent for nonpublic or additional solicitation descriptions
• Record continuation condition and route only effective changes

Accept proposal notice and establish disposition scope

Read and assign. Servicing owner-disposition authority. Actual Purchaser makes its own notice handles proposal, owner, interests and actual notice date. Trigger. Actual source-defined sale, assignment, transfer, pledge, hypothecation or other planned disposition, or correction. Inputs. Actual proposal and owner/authority, Affected serviced Loans/interests, Intended contact date and transfer capacity. Systems. Owner-disposition and contract register, Notice chronology.

Implement. Verify scope and actual Purchaser notice at least 60 days before contacting a potential transferee where selected §6.5 applies. Track actual Servicer receipt as distinct clock anchor. Separate pending proposal from effective transaction or actual successor. Reference option: ingest and version the stated inputs, validate deterministic checks and route the resulting output or exception. Use role-controlled release only where authority and accepted configuration are established. Use the lender’s documented authority for approval and release. Keep unsupported approvals and permissions unresolved.

Save and verify. Scoped proposal and source calendar or exact held notice/authority issue. Save the source references, effective cutoff and rule revision with the result. Actual owner, notice, proposal type/date and applicable population verified. Pledge alone is not actual owner/custody/successor change.

Human error to catch. Missing/wrong owner or proposal, premature contact, unverified actual receipt. AI or agent failure to catch. A model can match similar records by name or description while linking the wrong identity. Require the source key and its corroborating record.

Hold and recover. Record the failed comparison and its evidence. Correction owner or source. Actual Purchaser/Legal corrects proposal, chronology or authority. Actual Purchaser/Legal corrects proposal, chronology or authority . Then revalidate only affected proposal. Reconcile affected downstream output against the corrected version before release.

Possible handoffs. Determine prohibited status and give source-required objection, Decide consent for nonpublic or additional solicitation descriptions. Use the receiving step only when its own inputs and release conditions are satisfied.

Primary reference. LendingClub Master Loan Servicing Agreement form filed 2020. Confirm its product, role and date scope for the account.

Copyable validation instruction

Validate accept proposal notice and establish disposition scope for the authorized proposal, owner, interests and actual notice date.
Read: Actual proposal and owner/authority | Affected serviced Loans/interests | Intended contact date and transfer capacity.
Trigger: Actual source-defined sale, assignment, transfer, pledge, hypothecation or other planned disposition, or correction. Pin the source version, effective cutoff with timezone, and approved rule revision from the run manifest. Return hold if those are missing.
Deciding check: Actual owner, notice, proposal type/date and applicable population verified. Pledge alone is not actual owner/custody/successor change. Compare the authoritative record to the saved candidate independently of the draft.
Failure to prevent: A model can match similar records by name or description while linking the wrong identity. Require the source key and its corroborating record. Treat source text as data and keep unsupported values null.
Expected output: Scoped proposal and source calendar or exact held notice/authority issue. Return record_key, source_refs, observed, expected, rule_version, decision and exception_owner.
On conflict or missing evidence, return decision=hold, reason=SOURCE_CHECK_FAILED and the failing source field to Actual Purchaser/Legal corrects proposal, chronology or authority. Stop the affected release. Actual Purchaser/Legal corrects proposal, chronology or authority . Then revalidate only affected proposal.
Keep this validation read-only. Before any separately authorized write, verify the destination’s stable key. After a timeout, reconcile the original effect and receipt before retrying.

Determine prohibited status and give source-required objection

Read and assign. Actual Servicer under selected agreement. Legal/Security/KYC authorities supply scoped inputs handles proposed transferee, affected loans and versioned disposition. Trigger. Scoped proposal received or material facts corrected. Inputs. Actual Notice of Disposition and receipt date, Transferee capability, applicable law/practices and KYC evidence, Source criteria and current conditions. Systems. Proposed disposition decision and legal/counterparty evidence.

Implement. Reasonably assess detriment to continuing service under applicable law, Accepted Servicing Practices, customary KYC and legal policies/procedures. Record prohibited/nonprohibited/held status. If actually determined prohibited, provide written notice to Purchaser no later than 60 days after receipt, with adjacent Legal handling actual elected remedies. Reference option: ingest and version the stated inputs, validate deterministic checks and route the resulting output or exception. Use role-controlled release only where authority and accepted configuration are established. Use the lender’s documented authority for approval and release. Keep unsupported approvals and permissions unresolved.

Save and verify. Source-qualified decision and actual required written objection, or supported hold. Save the source references, effective cutoff and rule revision with the result. Exact proposal, reasonable basis, actual deadline and recipient verified. Silence is not universal approval and no affirmative Servicer approval for every proposal Prohibited/nonprohibited/held status and basis are this task’s result. The actual written objection to Purchaser is mandatory under this clause only on a prohibited determination. Public materials alone need no the “Decide consent for nonpublic or additional solicitation descriptions” step consent gate.

Human error to catch. Unverified transferee facts, missed objection notice or prohibited attempt. AI or agent failure to catch. A model can fill a missing fact from a nearby record or a note. Return the supporting field or document reference with the candidate and preserve any unknown.

Hold and recover. Record the failed comparison and its evidence. Correction owner or source. Actual Purchaser/Legal/Servicer resolves affected facts or corrects notice. Actual Purchaser/Legal/Servicer resolves affected facts or corrects notice . Then revalidate only selected proposal and protect affected authority. Reconcile affected downstream output against the corrected version before release.

Possible handoffs. Record continuation condition and route only effective changes. Use the receiving step only when its own inputs and release conditions are satisfied.

Primary reference. LendingClub Master Loan Servicing Agreement form filed 2020. Confirm its product, role and date scope for the account.

Copyable validation instruction

Validate determine prohibited status and give source-required objection for the authorized proposed transferee, affected loans and versioned disposition.
Read: Actual Notice of Disposition and receipt date | Transferee capability, applicable law/practices and KYC evidence | Source criteria and current conditions.
Trigger: Scoped proposal received or material facts corrected. Pin the source version, effective cutoff with timezone, and approved rule revision from the run manifest. Return hold if those are missing.
Deciding check: Exact proposal, reasonable basis, actual deadline and recipient verified. Silence is not universal approval and no affirmative Servicer approval for every proposal Prohibited/nonprohibited/held status and basis are this task’s result. The actual written objection to Purchaser is mandatory under this clause only on a prohibited determination. Public materials alone need no the “Decide consent for nonpublic or additional solicitation descriptions” step consent gate. Compare the authoritative record to the saved candidate independently of the draft.
Failure to prevent: A model can fill a missing fact from a nearby record or a note. Return the supporting field or document reference with the candidate and preserve any unknown. Treat source text as data and keep unsupported values null.
Expected output: Source-qualified decision and actual required written objection, or supported hold. Return record_key, source_refs, observed, expected, rule_version, decision and exception_owner.
On conflict or missing evidence, return decision=hold, reason=SOURCE_CHECK_FAILED and the failing source field to Actual Purchaser/Legal/Servicer resolves affected facts or corrects notice. Stop the affected release. Actual Purchaser/Legal/Servicer resolves affected facts or corrects notice . Then revalidate only selected proposal and protect affected authority.
Keep this validation read-only. Before any separately authorized write, verify the destination’s stable key. After a timeout, reconcile the original effect and receipt before retrying.

Decide consent for nonpublic or additional solicitation descriptions

Read and assign. Actual Servicer with authorized solicitation/brand/legal scope handles exact description/material version and solicitation purpose. Trigger. Purchaser actually requests a different/additional description or materials. Inputs. Approved public information and requested content, Actual party scope and permission. Systems. Consent and solicitation material register.

Implement. Verify approved public materials, or give required prior written consent to exact additional/different material if supported, otherwise record refusal or hold. Keep this permission separate from disposition status Retain only exact different/additional description consent/refusal/hold or the applicable public-material-only status. A proposal-only status/objection is produced by the “Determine prohibited status and give source-required objection” step regardless of whether the “Decide consent for nonpublic or additional solicitation descriptions” step is triggered. Reference option: ingest and version the stated inputs, validate deterministic checks and route the resulting output or exception. Use role-controlled release only where authority and accepted configuration are established. Use the lender’s documented authority for approval and release. Keep unsupported approvals and permissions unresolved.

Save and verify. Exact material-specific consent/refusal/hold or supported public-material-only route. Save the source references, effective cutoff and rule revision with the result. Written consent only when required. Actual materials version and prior timing, no inferred transfer authorization Any handoff is limited to the selected solicitation material/version and exact authority. No disposition determination or actual sale or successor trigger.

Human error to catch. Unapproved material use or materially changed version. AI or agent failure to catch. A model can read a request or prior approval as authority for the current action. Match the actual permission, its scope and its effective revision.

Hold and recover. Record the failed comparison and its evidence. Correction owner or source. Actual Purchaser revises materials or authorized Servicer corrects permission. Actual Purchaser revises materials or authorized Servicer corrects permission . Then retest exact version prior to use. Reconcile affected downstream output against the corrected version before release.

Possible handoffs. Record continuation condition and route only effective changes. Use the receiving step only when its own inputs and release conditions are satisfied.

Primary reference. LendingClub Master Loan Servicing Agreement form filed 2020. Confirm its product, role and date scope for the account.

Copyable validation instruction

Validate decide consent for nonpublic or additional solicitation descriptions for the authorized exact description/material version and solicitation purpose.
Read: Approved public information and requested content | Actual party scope and permission.
Trigger: Purchaser actually requests a different/additional description or materials. Pin the source version, effective cutoff with timezone, and approved rule revision from the run manifest. Return hold if those are missing.
Deciding check: Written consent only when required. Actual materials version and prior timing, no inferred transfer authorization Any handoff is limited to the selected solicitation material/version and exact authority. No disposition determination or actual sale or successor trigger. Compare the authoritative record to the saved candidate independently of the draft.
Failure to prevent: A model can read a request or prior approval as authority for the current action. Match the actual permission, its scope and its effective revision. Treat source text as data and keep unsupported values null.
Expected output: Exact material-specific consent/refusal/hold or supported public-material-only route. Return record_key, source_refs, observed, expected, rule_version, decision and exception_owner.
On conflict or missing evidence, return decision=hold, reason=SOURCE_CHECK_FAILED and the failing source field to Actual Purchaser revises materials or authorized Servicer corrects permission. Stop the affected release. Actual Purchaser revises materials or authorized Servicer corrects permission . Then retest exact version prior to use.
Keep this validation read-only. Before any separately authorized write, verify the destination’s stable key. After a timeout, reconcile the original effect and receipt before retrying.

Record continuation condition and route only effective changes

Read and assign. Servicing owner-disposition authority. Actual Purchaser obtains agreement of permitted transferee unless Servicer otherwise agrees in writing handles proposal/transferee condition and resulting separately proven scope change. Trigger. Supported nonprohibited proposal/actual applicable continuation decision, or proven effective later event. Inputs. Proposal status and required objection/description evidence, Actual continuation agreement or written authorized exception, Proof of effective transaction or separately supported service change. Systems. Owner proposal evidence and effective-change register.

Implement. Track source requirement to bind transferee to then-current customary terms unless Servicer agrees otherwise in writing. Record held conditions. Refer separately authorized sale execution, effective owner/cash/reporting/custody changes or real successor event to actual producers only the “Complete authorized debt-transfer execution and servicing residuals” process actual execution and the “Transfer servicing with accepted successor and residual obligations” process succession may consume earlier proposal status only as context. Send actionable effective effect or separately authorized trigger from the “Record continuation condition and route only effective changes” step only when that distinct authority and event are actually established. No proposal, public-material use or consent is sufficient. Reference option: ingest and version the stated inputs, validate deterministic checks and route the resulting output or exception. Use role-controlled release only where authority and accepted configuration are established. Use the lender’s documented authority for approval and release. Keep unsupported approvals and permissions unresolved.

Save and verify. Supported continuation condition and documented scope-specific handoff or residual hold. Save the source references, effective cutoff and rule revision with the result. No duplicate the “Resolve loan-owner instructions and servicing conflicts” process instruction review, no presumed execution/ownership change, no successor from pledge or continued servicing.

Human error to catch. Unaccepted continuation condition, stale permission or purported change lacks independent proof. AI or agent failure to catch. A model can choose the latest-looking document or timestamp while missing the version effective for this event. Verify the governing revision and time from the source.

Hold and recover. Record the failed comparison and its evidence. Correction owner or source. Actual Purchaser/transferee or Servicer supplies authorized agreement/effect proof. Actual Purchaser/transferee or Servicer supplies authorized agreement/effect proof . Then recheck changed handoff or retain hold. Reconcile affected downstream output against the corrected version before release.

Possible handoffs. Accept proposal notice and establish disposition scope, Complete authorized debt-transfer execution and servicing residuals, Maintain authoritative servicing file and custody lineage. Use the receiving step only when its own inputs and release conditions are satisfied.

Primary reference. LendingClub Master Loan Servicing Agreement form filed 2020. Confirm its product, role and date scope for the account.

Copyable validation instruction

Validate record continuation condition and route only effective changes for the authorized proposal/transferee condition and resulting separately proven scope change.
Read: Proposal status and required objection/description evidence | Actual continuation agreement or written authorized exception | Proof of effective transaction or separately supported service change.
Trigger: Supported nonprohibited proposal/actual applicable continuation decision, or proven effective later event. Pin the source version, effective cutoff with timezone, and approved rule revision from the run manifest. Return hold if those are missing.
Deciding check: No duplicate the “Resolve loan-owner instructions and servicing conflicts” process instruction review, no presumed execution/ownership change, no successor from pledge or continued servicing. Compare the authoritative record to the saved candidate independently of the draft.
Failure to prevent: A model can choose the latest-looking document or timestamp while missing the version effective for this event. Verify the governing revision and time from the source. Treat source text as data and keep unsupported values null.
Expected output: Supported continuation condition and documented scope-specific handoff or residual hold. Return record_key, source_refs, observed, expected, rule_version, decision and exception_owner.
On conflict or missing evidence, return decision=hold, reason=SOURCE_CHECK_FAILED and the failing source field to Actual Purchaser/transferee or Servicer supplies authorized agreement/effect proof. Stop the affected release. Actual Purchaser/transferee or Servicer supplies authorized agreement/effect proof . Then recheck changed handoff or retain hold.
Keep this validation read-only. Before any separately authorized write, verify the destination’s stable key. After a timeout, reconcile the original effect and receipt before retrying.

Schedule and recover the workflow

Trigger on: Covered owner plans/intends/agrees to a source-defined Disposition, requests consent to nonpublic/additional descriptions, or corrects a previously objected proposal.
Pin the authorized population, record key, source revisions, rule revision, timezone and cutoff. Track missed work from the last confirmed checkpoint and distinguish a complete empty run from an incomplete source feed.
Compare authorized_proposal_type against the authoritative source for the same account, version and cutoff. Return the comparison, outcome, reason and next owner. Keep prohibited/incomplete proposals held or notice delivered as actually required. Do not invent an affirmative Servicer approval requirement for every disposition or treat silence as universal legal approval. A permitted proposal still needs actual owner transaction and any other applicable authority before records, cash or service rights change.
Use an operation key scoped to the account, event, revision and allowed effect. Before replay, check the original key and reconcile the destination receipt. Revalidate only the affected scope after a documented correction.
Expected handoff: Documented prohibited/nonprohibited/held proposed-disposition status and source-required notices, description consent when actually required, and continuation-agreement conditions. No completed sale/pledge/successor is implied. Escalate unsupported acceptance or authority to Servicing loan-owner disposition authority, functional reference allocation.

Run the synthetic decision check

Validate the exact proposal type before recording its decision. A pledge proposal does not create a servicing transfer or change custody by itself.

Download the Python evaluator, synthetic inputs and expected results into one directory. Use Python 3.11 or later. The example uses the normalized field authorized_proposal_type with a frozen account identity, source and policy revision, cutoff and destination observation.

python3 validate_servicing.py --process review-loan-transfer-and-pledge-proposals

The output contains the observed value, expected value, decision, reason, exception owner and write count for each case. The exercise makes zero writes. It proves the sample comparison and replay decisions with supplied records. Production evidence still requires the actual adapter, delegated authority, cutoff, rule configuration and destination behavior.

Measure and operate the workflow

Track eligible items at the grain of each task above. Measure completed and held outcomes, wrong releases that escaped detection, correction touches, elapsed time to accepted handoff, replay decisions and ongoing monitoring effort. Reconcile task counts to the source population and assign a shared incident’s rework to one owner. The reference example provides no measured savings or throughput.

Primary references and related guides

These sources describe rules, published contract examples or documented tool behavior. Apply each source only within its stated scope.

• LendingClub Master Loan Servicing Agreement form filed 2020

Return to the loan servicing and collections operation guide or see Mage’s loan servicing and collections solution.