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Aloan
All industries

For community banks

AI commercial underwriting built for community banks

The credit file your examiner expects, without hiring three more underwriters. Aloan automates spreading, global cash flow, and credit memo generation for sub-$10B community banks — with source-cited audit trails that hold up under OCC, FDIC, and state exam.

Examiner-ready memos with citationsDeploy in 2–4 weeksSits on top of nCino, Abrigo, Baker Hill, or your existing LOSOCC, FDIC, NCUA, and state-regulator alignment

Why community bank lending is different

Community bank commercial lending sits in its own pressure window

Community banks under $10B in assets carry a commercial book that looks nothing like what nCino was originally built for. The deal mix is broader (CRE, C&I, SBA, ag in one credit team), the underwriting team is smaller (often 2–10 people total), the regulator is more involved per dollar of assets, and the pricing pressure from credit unions and fintechs is constant. AI underwriting has to fit those constraints, not fight them.

Deal mix

A typical community bank credit team handles CRE, C&I, SBA 7(a) and 504, owner-occupied real estate, equipment finance, and ag in the same week — often the same day. The platform has to handle all of it without per-product configuration overhead.

Regulator

OCC for nationally chartered banks, FDIC for insurance and many state-chartered, plus state regulators with their own exam scope. Exam cycles run 12–18 months and lean hard on credit file documentation.

Team size

Most sub-$1B community banks run a 2–6 person credit team handling 200–800 commercial credits per year. Manual spreading consumes 40–60% of that team's capacity before any credit judgment happens.

Concentration pressure

CRE concentrations above the FDIC/OCC 100/300 capital thresholds get supervisory scrutiny. Banks at or near the threshold need stronger per-deal documentation and portfolio monitoring than the LOS alone produces.

Why Aloan

Built around the way community banks actually run credit

The platform's defaults assume a small credit team, examiner pressure, broad deal mix, and an existing core/LOS investment that nobody wants to rip out.

01

Examiner-ready output, not a black box

Every figure in every spread and credit memo links to the exact page and line of the source document. When the OCC examiner asks where a number came from, the analyst clicks one link. SR 11-7 model risk documentation is included; OCC Bulletin 2023-17 third-party governance is addressed.

02

No LOS replacement

Aloan sits on top of nCino, Abrigo, Baker Hill, MeridianLink, Encompass, or even an Excel-based workflow. No data migration. No Salesforce platform fee. No 12-month implementation. Most community banks are live in 2–4 weeks.

03

Handles the broad deal mix

CRE, C&I, SBA, owner-occupied, equipment, and ag — one platform, one workflow. Tiered K-1 tracing across guarantor entities. Schedule F for farm operators. Rent roll and T-12 normalization for CRE. The platform was designed for the community bank deal mix, not retrofitted for it.

04

Pricing that works for small teams

Volume-based pricing rather than seat licenses. A 2-person credit team that processes 300 commercial credits per year does not pay enterprise-platform pricing. Most sub-$1B institutions see ROI on the first 30–50 deals.

05

Multi-entity reasoning, not single-form OCR

Borrower owns three LLCs, two of which own pieces of a fourth, with a personal guarantor whose 1040 ties back to all of it. Aloan builds the entity graph, traces K-1 distributions across tiered ownership, reconciles intercompany activity, and produces the global cash flow without an analyst rebuilding it in Excel.

06

Stays out of the credit decision

Aloan is decision support, not a decision engine. The platform produces the spread, the analysis, and the draft memo. The credit officer reviews, overrides where judgment is needed, and approves. Every change is logged. The credit decision authority stays with the bank — which is also what FFIEC and OCC expect.

Built for the exam cycle

Designed to survive the exam, not to make it harder

Aloan was built for regulated banking from day one. Every output is auditable, every model decision is documented, and the governance posture aligns with the major community bank regulators.

OCC Bulletin 2023-17 and OCC 2025-26

Aloan addresses the OCC's third-party AI risk management expectations: documented model behavior, vendor SOC 2 Type II coverage, decision authority retained by the bank, and a traceable record of how outputs were generated. The 2025-26 generative AI guidance is the explicit framework Aloan is built against.

SR 11-7 model risk management

Aloan provides the model documentation, validation evidence, monitoring, and ongoing performance tracking that SR 11-7 expects. Banks integrate Aloan into their existing model inventory with the documentation pack provided at implementation — no separate validation engagement required.

FFIEC IT examination handbook alignment

Information security, vendor management, business continuity, and audit logging all align with FFIEC IT exam expectations. The Aloan SOC 2 Type II report is available under NDA via the Trust Center; Vertex AI and AWS Bedrock provide the underlying SOC 2 Type II AI infrastructure.

CFPB 1071 small business data collection

Aloan produces the application-and-decision documentation trail that simplifies 1071 audit response. Demographic data fields are passed through cleanly; underwriting reasoning is reproducible if a fair lending review is initiated.

Read the full Examiner Readiness Guide for SR 11-7, OCC Bulletin 2023-17, and OCC 2025-26 details.

What changes day one

What changes the week Aloan goes live

These are the operational shifts community bank credit teams report after Aloan goes into production. Concrete, day-to-day changes — not vendor abstractions.

  • Spreading time per credit drops from 2–4 hours of analyst time to 10–20 minutes of analyst review
  • Multi-entity tax-return packages that used to take a half-day are reconciled and ready in the morning
  • Credit memo first-draft turnaround moves from 3–5 days to same-day on most credits
  • Analyst capacity per team member roughly doubles — same headcount handles meaningfully more deal flow
  • Examiner walkthrough of any credit takes minutes: every number clicks through to its source page
  • CRE concentration documentation tightens: stronger per-deal stress and sensitivity, easier portfolio reporting
  • Onboarding a new analyst gets faster: standardized output reduces the on-the-job spread-template training period
  • Senior credit officers stop touching keystroke work and spend their week on actual credit judgment

FAQ

Common questions

Will an OCC, FDIC, or state examiner accept AI-generated credit memos?

Yes, when the output is properly cited and the bank has the model risk governance to back it up. Examiners do not have an objection to AI-generated analysis itself — their objection is to analysis that cannot be reproduced or traced. Aloan addresses both: every figure in a generated memo links back to the exact page of the source document, and the platform aligns with SR 11-7 model risk management expectations and OCC Bulletin 2023-17 guidance on third-party AI. Community banks deploying Aloan typically present the audit trail directly to examiners during loan file review and have not seen MRA findings tied to the AI output.

How does Aloan compare to nCino, Abrigo, or Baker Hill for a community bank?

nCino, Abrigo, and Baker Hill are loan origination systems — they replace your workflow stack and typically take 6–18 months to implement. Aloan is an AI-powered underwriting overlay that sits on top of whichever LOS you already use (or alongside an Excel-based workflow) and automates the underwriting analysis layer specifically. Banks pick Aloan when the bottleneck is spreading and credit memo prep, not pipeline management. Many community banks run Aloan on top of an existing nCino, Abrigo, Baker Hill, or Encompass deployment.

How long does Aloan take to deploy at a community bank?

Two to four weeks from signed contract to first deal in production. Implementation includes credit policy configuration, spread template setup to match the bank's standardized format, user provisioning, and a brief governance review. There is no data migration, no Salesforce platform fee, no consulting engagement, and no need to retire your existing LOS or core integration. Larger institutions with stricter governance reviews may take longer; sub-$1B institutions are often live within two weeks.

Does Aloan handle CRE concentration analysis and 300% capital guidance?

Yes. Aloan generates the per-deal CRE analysis (NOI normalization, DSCR stress, debt yield, sponsor global cash flow) and supports the portfolio-level reporting needed to monitor CRE concentration against the FDIC/OCC interagency 100/300 thresholds. Banks already at or above the 300% supervisory threshold use Aloan to strengthen the per-deal documentation that supervisors expect when concentration scrutiny intensifies — including stress testing, sensitivity analysis, and source-cited analyst conclusions on every credit.

Can Aloan support a community bank running on Jack Henry, FIS, or Fiserv core systems?

Yes. Aloan is core-agnostic. The platform sits in the underwriting analysis layer and integrates with whatever LOS or core system the bank already uses. For banks on Jack Henry SilverLake, FIS Horizon or IBS, or Fiserv Premier or DNA, Aloan delivers the spread, analysis, and credit memo output that gets attached to the credit file in the bank's existing system of record. No core replacement required.

How does Aloan support 1071 small business lending data collection?

CFPB 1071 reporting requires consistent, defensible data on demographic and business information for every small business credit application. Aloan helps in two specific ways: the platform produces standardized application packages and decision documentation that simplify the audit trail required for 1071, and the source-cited analysis ensures that the underlying decision rationale is reproducible if a 1071 fair lending review is initiated. Aloan does not file 1071 reports for the bank, but it produces the underwriting record that makes 1071 compliance defensible.

What does Aloan cost for a community bank under $1B in assets?

Pricing is tied to deal volume rather than seat count, which works well for community banks with small underwriting teams that handle a meaningful flow of commercial credits. Most sub-$1B institutions land in a five-figure annual range with no implementation fees. The relevant comparison is staff hours saved per deal — most banks see Aloan pay for itself on the first 30–50 commercial credits processed through the platform.

How does Aloan handle ag lending, multifamily, owner-occupied CRE, and other community bank specialties?

Aloan handles the document mix typical of community bank ag, multifamily, owner-occupied CRE, and small C&I deals — including farm tax returns (Schedule F), rent rolls, T-12 operating statements, business tax returns with tiered K-1s, and personal financial statements for guarantors. The platform spreads, traces, and reconciles these document types with source citations. For ag lending specifically, Schedule F income, FSA documentation, and crop insurance summaries are supported.

Can a community bank with a 2-person credit team realistically use AI underwriting?

Yes — small teams are arguably the highest-leverage use case. The constraint at a small community bank is rarely loan demand; it is the underwriting-hours bottleneck. Aloan removes the keystroke labor from spreading, global cash flow, and memo drafting so a 2-person credit team can process the deal flow that used to require 4–5 people. Senior credit officers stay in the credit decision; the platform handles the document work that used to take their week.

Other institutions

See Aloan for other institution types

See Aloan run on a real community bank deal

Bring a representative credit file — multi-entity, tiered K-1s, the works. We will show you the spread, the global cash flow, and the draft memo in the demo, with your bank's standard format applied.