1
Define the scope and identify excluded transactions
Name the legal entity the policy covers and list every loan type in scope β employee advances, shareholder loans, intercompany lending. Then explicitly list what is excluded, such as trade credit or operating-lease obligations.
π‘ A clear exclusion list prevents scope disputes during audits far more reliably than a broad inclusion statement.
2
Set approval authority tiers with specific dollar thresholds
Create at least three tiers β manager, CFO, and board β with dollar ranges for each. Ensure the thresholds reflect your organization's actual transaction sizes so the policy is used in practice.
π‘ Set the board-approval threshold 20β30% above your largest likely single loan, so routine transactions don't require a special board meeting.
3
Define borrower eligibility and disqualification rules
State minimum tenure, employment status (permanent vs. contract), and any automatic disqualifiers such as active disciplinary proceedings or prior loan defaults with the organization.
π‘ Run this section past HR before finalizing β eligibility rules that conflict with employment policies create grievance risk.
4
List required documentation with a pre-disbursement checklist
Enumerate every document required before a loan is funded and build it into a checklist that the approving officer signs. Common items: signed loan agreement, promissory note, proof of purpose, and collateral documentation.
π‘ Attach the checklist as a policy appendix rather than embedding it in the body β it is easier to update independently as requirements change.
5
Set the interest-rate floor linked to the current AFR
State the minimum rate as 'the short-term IRS Applicable Federal Rate for the month of disbursement' rather than a fixed percentage, so the policy stays compliant as rates change.
π‘ Task the CFO to document the AFR on the date of each disbursement and attach it to the loan file β this is the primary evidence in an IRS audit of below-market loan claims.
6
Specify collateral thresholds and perfect security interests
State the loan size above which collateral is required, the minimum LTV ratio, and acceptable collateral types. Include a requirement that a UCC-1 financing statement or equivalent lien be filed before disbursement for secured loans.
π‘ Never rely on a promise to provide collateral after disbursement β by that point there is no practical way to enforce it without suing the borrower.
7
Write the related-party lending section last and have it reviewed
Draft the related-party section after all other sections are finalized so you can cross-reference the standard terms. Require independent director approval and annual financial-statement disclosure for all related-party loans.
π‘ For nonprofits, mirror the language from IRS Form 990, Part VI, Schedule L β it will satisfy the form's disclosure requirements directly.
8
Obtain board adoption and schedule an annual review
Present the completed policy to the board for formal adoption by resolution, record the adoption date, and set a calendar reminder for annual review β particularly to update the AFR reference and approval thresholds.
π‘ Version-control the policy with a header showing the adoption date and next scheduled review date so auditors can confirm it is current.