A closing condition is complete when the party authorized to clear it has the required evidence and records the disposition. Track dependencies and financial effects so a high completion percentage does not conceal a critical blocker.
Track each funding condition as a decision with evidence, an owner and an authorized reviewer. This prevents a folder full of documents from being mistaken for a file ready to fund. The checklist’s status should reflect actual events, not a desired closing date.
The OCC handbook describes credit-file and disbursement controls. This original register is a coordination aid based on the actual lender’s conditions. It is not a universal list of what every commercial loan requires.
Establish the controlling condition list
Record the latest condition list, commitment and applicable document references. Reconcile changes with the lender’s team and counsel. A condition deleted from an internal borrower spreadsheet has not thereby been waived.
Give each condition a stable ID and identify prerequisites. A reserve amount may depend on a technical scope review; verified equity may then depend on that reserve amount. Model the dependency so a downstream item is not marked complete prematurely.
Blank condition tracker
condition_id,requirement_and_source,prerequisite_ids,responsible_party,due_date,required_evidence,clearance_authority,status,funding_effect
C001,,,,,,,open,
Field instructions
| Field | Record | Avoid |
|---|---|---|
| requirement_and_source | Exact requirement and current version | Relying on an old checklist after terms change |
| prerequisite_ids | Conditions that must be resolved first | A due date with no feasible dependency sequence |
| responsible_party | Person preparing the evidence | Confusing preparer with clearance authority |
| required_evidence | Defined completion evidence | “Docs” or “done” without a record |
| clearance_authority | Actual designated reviewer | Assuming every loan-team member can waive a term |
| funding_effect | Cash, timing or legal consequence | Treating every incomplete item as equally important |
Completed hypothetical tracker
condition_id,requirement_and_source,prerequisite_ids,responsible_party,due_date,required_evidence,clearance_authority,status,funding_effect
C001,Repair scope; hypothetical lender condition list v3,RPT002,Project manager,2026-11-12,Accepted scope and contractor budget,Lender technical reviewer,under_review,Reserve amount depends on accepted scope
C002,Repair reserve; hypothetical condition list v3,C001,Sponsor,2026-11-14,Revised sources and uses plus verified equity,Lender credit/closing team,blocked,"Additional $100,000 reserve and $75,000 lower advance require $175,000 more equity if reserve is incremental"
C003,Entity borrowing authority; document checklist v2,None,Borrower counsel,2026-11-13,Executed required consent/resolution,Lender counsel,delivered_not_cleared,Funding cannot rely on unsigned or unaccepted authority
C002 is blocked by C001 because the reserve cannot be finalized until the repair scope is accepted. C003 is delivered but not cleared. Its document may be physically present while the legal review remains unresolved.
If nineteen of twenty conditions are complete, the count is 95%. That statistic does not establish a 95% probability of funding. One unresolved authority, title or equity condition can still prevent the transaction from closing.
The sample funding effect assumes a genuinely incremental $100,000 repair reserve plus a $75,000 reduction in the initial advance. Together they require $175,000 additional equity, holding other uses constant. If the reserve funds work already budgeted, that portion must be reclassified rather than counted twice.
Manage a material change
When a finding changes proceeds or required cash, update sources and uses, liquidity evidence and any approval dependent on the old structure. Assign those updates their own conditions instead of closing the original issue while leaving related records inconsistent.
If a waiver or amendment is proposed, record it as proposed until the required authority and evidence establish its effect. Counsel should evaluate actual documentation and legal consequences. A cooperative conversation does not by itself clear a contractual funding condition.
Use the final review to reconcile evidence
Before funding, compare the tracker with the lender’s current list and the closing coordinator’s instructions. Confirm that clearances apply to the final borrower, amount, property and document version. Record unresolved exceptions and the party deciding their disposition.
Retain the final tracker and clearance evidence after closing. Conditions that survive funding should transfer to the covenant or post-closing calendar with their actual deadlines. The register should explain how the file reached funding and what obligations remain.
Sources and evidence
- OCC — Commercial Real Estate LendingPrinted page 51: File Documentation; pages 48–49: Disbursement Processes · Checked 2026-10-21 · Handbook version 2.0 published March 2022. Supervisory context; these original templates are optional and do not establish lender requirements.
Source dates and applicability matter. Report an error or a changed source.