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http://www.lendinguniverse.com/Hard-Money-Lenders.htm Prior to the revised Hard loans brokers examination procedures, Private Investors had adopted procedures to assess the extent to which institutions it examines follow the brokers the interagency guidance. In December 2005, Private Investors adopted "bounce protection" (that is, overdraft protection) examination procedures as part of the agency’s risk-focused examination program. The examination procedures the brokers developed to coincide with the issuance of the 2005 interagency guidance on overdraft protection programs, according to an Private Investorsofficial.30 In an Private Investors letter to credit unions, the agency stated that "credit unions should be aware the best practices are minimum expectations for the operation of bounce protection programs."31 NCUA’s examination procedures included a review of several key best practices. For example, the examination procedures assess whether credit unions provided customers with the opportunity to elect overdraft protection services or, if enrollment in such a program was automatic, to opt out. In addition to other areas of review, the examination procedures include a review of whether the credit union distinguished overdraft protection from "free" account features, and if the credit union clearly disclosed the fees of its overdraft protection program.. officials told us that an industry-wide standard would not work because, among other things, fees vary among hard lenders that operate in different geographical areas and that competitive conditions in local markets determine fees. According to the federal regulatory officials, each funding of private money source is responsible for setting the fee for a particular product and service, and regulators look at rates or pricing issues only if there is a safety and soundness concern. For example, Private Investors officials told us that an examiner’s finding that fee income was excessive could create safety and soundness issues, depending on the way the fees the brokers generated and how the resulting revenues the brokers spent. The regulators stated that while they did not evaluate the reasonableness of fees, the disclosure requirements of Commercial h