# Dental-practice loan data-boundary checklist

Use this before sending a complete application, personal financial statement, target valuation, contractor budget, or equipment quote. It is a conversation and documentation aid—not a legal demand or conclusion. Have counsel adapt it to the lender, loan program, documents, and state.

## Identify every recipient

- Bank employees and committees that need access.
- Affiliates and parent companies.
- Underwriting, appraisal, valuation, document, closing, servicing, security, and technology providers.
- Dental brokers, consultants, contractors, equipment vendors, insurers, accountants, attorneys, and referral partners.
- Marketplaces, lead generators, marketing partners, and joint programs.

For each recipient, record the legal name, relationship, purpose, data fields, authorization, retention period, safeguards, onward-disclosure rights, and referral compensation.

## Protect the negotiation ceiling

- Ask the lender not to disclose the requested amount, maximum approval, liquidity, personal financial statement, projections, appraisal, target asking price, or contingency without a necessary purpose and written confirmation.
- Give contractors and equipment vendors only the approved scope, specifications, and budget relevant to their quote—not the maximum loan.
- Ask whether proof of funds can be stated as “sufficient for the proposed transaction” or otherwise redacted.
- Keep lender selection separate from seller, broker, contractor, and equipment-vendor selection.
- Obtain at least three comparable lender proposals using the same borrower and target package.
- Record every lender-introduced professional, what the lender said about them, and any disclosed compensation or preferred relationship.

## Ask in writing

> Before I provide additional financial information, please identify every non-bank recipient that may receive any part of my application or underwriting file, the specific data fields, purpose, legal or contractual basis, retention period, safeguards, and any referral compensation. Unless required to process or service the loan and confirmed to me in writing, please do not disclose my requested amount, approval ceiling, personal financial statement, liquidity, projections, appraisal, or vendor budget to any broker, seller, contractor, equipment vendor, consultant, or marketing/referral partner without my separate written authorization.

## Compare the actual loan

- Rate, index, margin, floor, fixed/variable period, amortization, maturity, and payment.
- Fees, deposits, insurance, hedging, prepayment, late/default rate, and closing cost.
- DSCR calculation, normalization, global cash-flow assumptions, collateral, lien position, and personal guaranty.
- Equity injection, seller-note treatment, standby requirements, holdback/escrow restrictions, and contingent-payment restrictions.
- Working capital, construction overruns, equipment, leasehold, real estate, refinancing, and post-close covenant treatment.
- Appraisal/valuation scope, author, independence, reliance rights, ownership, full-report access, and reconsideration process.
- Closing conditions, expiration, material-adverse-change language, assignment, credentialing assumptions, and required professionals.

## Legal scope warning

Federal Regulation P applies to nonpublic personal information about individuals obtaining financial products primarily for personal, family, or household purposes. It expressly says it does not apply to information about companies or people obtaining products for business, commercial, or agricultural purposes. Do not assume a consumer privacy notice controls a dental-practice loan. Other statutes, regulations, bank duties, policies, contracts, consents, and state law may apply. Obtain transaction counsel for the actual facts.

Primary references:

- CFPB Regulation P scope: https://www.consumerfinance.gov/rules-policy/regulations/1016/1
- CFPB Regulation P definitions: https://www.consumerfinance.gov/rules-policy/regulations/1016/3
- OCC interagency third-party risk guidance: https://www.occ.treas.gov/news-issuances/bulletins/2023/bulletin-2023-17.html
- ADA guidance to compare at least three banks: https://www.ada.org/resources/careers/career-planning/articles/talk-to-3-banks-the-first-step-in-buying-a-dental-practice