NJ UCC filing threshold changes since 2019 - what am I missing?

That's what I thought too, but they're insisting something changed in 2019. Maybe it's an internal risk management thing they're calling a 'threshold'? Thanks for confirming the basic rule though.

Your bank might be thinking of SBA loan requirements or some federal regulation that kicked in around then. Those sometimes have dollar thresholds for different procedures.

This makes sense. They might be confusing 'when we take security' with 'when we have to file UCCs.' I'll dig into our loan policies from that timeframe.

Exactly right. Lots of banks set internal minimums for secured lending but that's totally different from filing requirements once you do take security.

Wait I'm confused now. If there's no threshold then why do some of our smaller loans not have UCC filings? Are we doing something wrong?

That's interesting - so you found loans where you should have filed but didn't? That might be exactly what's happening here. How does that verification tool work?

Really straightforward - you just upload PDFs of your loan agreements and UCC forms and it automatically checks if the debtor names match, collateral descriptions align, everything's consistent. Caught stuff our manual reviews missed.

This sounds like exactly what we need. Our manual compliance checks are a nightmare and we definitely miss things.

Have you checked if she's thinking of the beneficial ownership rules that changed around then? Those have thresholds but they're not UCC related.

Oh snap that might be it! She does handle BSA compliance too. I bet she's mixing up the beneficial ownership thresholds with UCC stuff.

That timeline matches up perfectly. They probably got confused between system changes and rule changes. Thanks for that insight.

System updates are the worst. Half the time they change the forms or procedures and everyone panics thinking the law changed.

Why can't they just leave the systems alone? Every update breaks something else.

We only do business in NJ so it shouldn't be a cross-state confusion issue. But good point to double-check.

NY rules are completely different anyway. Their filing requirements are more about the type of collateral than the amount.

That's a great point. I should look at our actual filing numbers from 2019 vs other years. Maybe the 'change' was just business volume.

2019 was weird for a lot of banks. Interest rates, regulatory uncertainty, lots of factors affecting lending patterns.

Yeah we definitely tightened our lending standards that year. Probably explains a lot of 'policy changes' people remember.

Good to know the verification tool is catching those types of issues. Sounds like it would definitely spot major compliance gaps.

How thorough is that verification? Does it check everything or just basic stuff?

It's pretty comprehensive - checks debtor names against your loan docs, makes sure collateral descriptions match, flags missing or inconsistent filings. Really helped clean up our records.

A threshold would mean you only have to file UCCs on loans over a certain dollar amount. But that's not how UCC filings work - if you take a security interest, you file, regardless of the loan size.

Ohhhh okay that makes sense. So there's no such thing as a UCC threshold in NJ. Got it, thanks.

Some states do have thresholds for other types of liens but not UCCs. Easy to get confused.

Classic compliance team move. Glad you got it sorted out!

Nice work tracking it down. Definitely consider running those verification checks to make sure you didn't miss any actual filings during the confusion.

This thread was super helpful. Saving it for the next time someone on our team gets confused about filing requirements.