Collections - GAAP vs. Reasonableness

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Heather E

I just wrapped up a hefty look into our collection practices and one part wasn’t sitting well with me.  Every single collection expense we incur is running through a collection expense GL and sometimes the expenses are noted as a comment in the account or are just added physically into a paper file.  I am finding that these expenses are:1) not included with total charge offs reported to and approved by the Board;2) not accounted for when determining if there is a deficiency balance after the asset is sold;3) not included when the deficiency balances are sent off to a third-party collection agency; and4) there is no balancing of the GL or other second look at the expenses to determine reasonableness and legitimacy.  When trying to find a reasonable solution, staff are not wanting to add these collection expenses as specific loan add-ons because the loan balance has already been written down to FMV and this would re-inflate the asset.  As to #4, the control issue, our VP of Lending handles and oversees all of lending and collections and is the person who handles our foreclosures from beginning to end...so this is the reason for my concern. I know this is a very loaded question so I greatly appreciate any and all advice from those more experienced than me.  Thanks in advance!!