Derek P. Pollard — Managing Partner
Former Federal Reserve Examiner and SunTrust CRE Risk Executive with oversight of a $26B portfolio. Now leading LakeRock Capital in blending regulatory mastery with AI-powered innovation.
📊 $26B CRE Portfolio Oversight I 📈 103% CRE Portfolio Growth at SunTrust (Truist) I🏦 Former Federal Reserve Examiner I
Executive Summary
Derek blends supervisory insight with front-line credit execution. He has led complex CRE underwriting, credit policy, and portfolio oversight across cycles, and now applies that discipline to client mandates, pairing traditional risk frameworks with modern AI automation.
He treats risk management and loan production as a single operating system – not competing goals. He translates risk appetite into deal-level guardrails that speed “clean approvals” while preserving portfolio integrity across cycles. The result is a faster, more predictable credit process that defends capital, satisfies examiners, and still hits production targets.
30+ years of commercial real estate credit & risk management across lending, underwriting, and portfolio management.
Former Federal Reserve Examiner with deep knowledge of capital markets, credit risk, and OCC/FDIC/FRB expectations.
Enterprise-level leadership in underwriting frameworks, credit policy, governance, and examiner-ready documentation.
AI & automation advocate, building practical workflows for underwriting, policy review, and document intelligence.
Challenge:
Transform the commercial real estate credit risk strategy and infrastructure to support rapid portfolio growth while maintaining full regulatory alignment.
Role & Scope:
Led credit risk strategy for SunTrust’s $26.0 billion CRE portfolio, overseeing underwriting standards, portfolio analytics, risk governance, and regulatory engagement.
... while meeting Basel III capital standards and regulatory exam expectations.
... that standardized risk assessment, loan structuring, and approval workflows across CRE lending verticals.
... during an economic downturn through proactive credit policy recalibration.
... improving model accuracy by 30% and supporting Basel-aligned capital planning.
... by redesigning collateral management and risk identification processes.
... aligning credit strategy with SunTrust’s growth and regulatory imperatives.
Signature Accomplishments
Federal Reserve Bank of Atlanta
Led regulatory examinations of commercial real estate lending, capital markets, and liquidity risk at banks managing $50.0 billion to $300.0 billion in assets, strengthening supervisory oversight and institutional risk controls.
Improved regulatory compliance and institutional ratings by ~20% through targeted reviews of credit risk management, internal controls, and model validation.
Directed capital markets risk reviews covering treasury, derivatives, and interest rate models, ensuring alignment with safety-and-soundness standards.
Developed examiner frameworks and reporting protocols that enhanced consistency and accuracy in CRE and capital markets supervisory findings.
Commissioned Federal Reserve Examiner — recognized for expertise in risk management, compliance, and enterprise supervision of complex financial institutions.
Track Record: Risk, Capital, and Execution
From Enterprise Credit Risk Executive to Federal Reserve examiner, lender, and operator, Derek’s experience spans nearly the full CRE stack. This section demonstrates how he balances growth and safety across underwriting, policy, capital markets, and AI-driven efficiency, serving banks, sponsors, and investors, including his experience at LakeRock Capital and HealthTouch.
Click on Each Box for more Information:
Summary: Leads a risk-first advisory and AI automation firm serving banks, developers, and investors. Combines enterprise credit discipline with regulator-aligned workflows and technology that shortens cycle time without lowering standards.
Scope & Responsibilities
- Set firm strategy and delivery standards across bank advisory, CRE analytics, capital placement, and AI automation.
- Translate risk appetite into deal-level guardrails (LTV/DSCR/debt-yield, recourse tiers, covenants) and operating SOPs.
- Architect examiner-ready credit memos, templates, and workpapers mapped to OCC/FDIC/FRB expectations.
- Direct buildout of UnderwriteIQ™ and related GPT/automation modules (lease/appraisal/title abstraction, policy review, memo drafting).
- Hire and manage specialist contractors for selected assignments, matching experience level to task complexity and budget; enforce LakeRock standards, NDAs, and QC checkpoints.
- Oversee client engagements end-to-end: scoping, underwriting/analytics, governance redlines, and implementation.
Programs & Initiatives
- UnderwriteIQ™ Platform: AI-assisted underwriting and credit-memo generation; elimination of redundant keystrokes; normalized analyses.
- Policy & Governance Modernization: SR 11-7–informed documentation, delegation matrices, exception logic, and QA/independent review.
- CRE Analytics & Feasibility: Market absorption, downside cases, and break-even logic tied to pricing and structure.
- Capital Advisory: Capital-stack design (senior/mezz/pref/JV), lender fit, and term-sheet comparisons for defensible execution.
Risk Management & Governance
- Green/Yellow/Red deal guardrails by asset/market/sponsor; compensating-factor framework for controlled exceptions.
- Stress & sensitivity cases (rate, NOI, exit cap) wired into terms, reserves, and covenants; feedback into CECL/expected-loss views.
- Audit-ready documentation aligned to FIRREA, SR 11-7, and interagency manuals; clear retention and change control.
Outcomes
- Cleaner, faster approvals and reduced rework through standardized intake and memoing.
- Stronger exam readiness and more predictable supervisory interactions for bank clients.
- Scalable production for sponsors/investors via structure discipline and market-grounded analytics.
Summary: Led enterprise underwriting standards, credit policy, and portfolio governance for a multi-billion CRE platform; balanced production goals with examiner-ready risk controls and operating discipline.
Scope & Responsibilities
- Set risk appetite guardrails (LTV/DSCR/debt-yield, recourse tiers, covenants) by asset/market/sponsor.
- Owned credit policy, strategy, guidelines, & procedures, delegated authority matrices, exception governance, and QA/independent review.
- Standardized underwriting templates & credit memos; implemented pre-screen triage and “speed-to-yes” workflows.
- Directed concentration management (asset class, MSA, sponsor/tenant), pipeline mix, and limit monitoring using coding logic.
- Led stress testing & CECL/expected loss feedback loops; integrated findings into pricing and structure.
- Managed exam readiness (OCC/FDIC/FRB, FIRREA, SR 11-7) with full workpaper/audit-trail discipline.
- Drove data & systems improvements (nCino/Salesforce workflows, document intelligence intake, reporting).
Enterprise Programs & Transactions
- Built and governed an enterprise CRE underwriting platform (~$26B) spanning construction, bridge, and perm.
- Portfolio diagnostics and policy modernization across cycles; special assets triage and remediation playbooks.
- Capital markets coordination on structure, term sheets, and risk-adjusted pricing (RAROC/ROE alignment).
Risk Management & Governance
- Green/Yellow/Red deal guardrails; compensating-factor logic for controlled exceptions.
- Sensitivity & downside cases (rate, NOI, exit cap) tied directly to terms, reserves, and covenants.
- Early-warning & surveillance: covenant triggers, watchlist criteria, and remediation timelines.
- Documentation standards aligned to FIRREA, SR 11-7, OCC/FDIC/FRB expectations.
Outcomes
- Cleaner, faster approvals with lower rework; consistent file quality across regions.
- Stronger exam performance and smoother supervisory interactions.
- Scalable production without diluting standards; improved concentration posture and pricing discipline.
- Foundation for AI-enabled automation later advanced via LakeRock AI/UnderwriteIQ™.
Summary: Originated, structured, and underwrote large-balance CRE loans across income-producing assets and for-sale development (residential/condo/subdivision), from term to A&D/construction.
Scope & Responsibilities
- Sourced and qualified sponsor and asset pipelines; led term-sheet negotiations and credit structuring.
- Full underwriting: rent rolls, T-12s, pro formas, market comps, cap-rate/exit sensitivity, DSCR and debt-yield analysis.
- Construction/A&D: absorption studies, release pricing, presale/prelease tests, contingency and interest-reserve sizing.
- Drafted examiner-ready credit memos; coordinated third parties (appraisal, environmental, PCA), legal, and closing.
- Monitored covenants, draws, and performance; escalated early-warning indicators and remediation plans.
Representative Transactions
- Income-Producing: Multifamily, medical office, Low income housing tax credit (LIHTC), industrial, grocery-anchored retail (stabilized and value-add).
- For-Sale Development: Urban condo, SFR subdivisions, mixed-use phases with vertical and horizontal improvements.
- Structures: Senior construction and mini - perm loans; select mezz/pref participation alongside senior executions.
Risk Management & Governance
- Guardrails by asset/market: LTV/DSCR/debt-yield bands, recourse tiers, lease-up and absorption thresholds.
- Stress testing: rate shocks, NOI variance, exit cap expansion; tie-backs to structure and covenants.
- File quality and documentation aligned with OCC/FDIC/FRB expectations and internal policy.
Outcomes
- Faster “clean approvals” with fewer exceptions; on-time closings and strong exam results.
Improved sponsor selectivity and portfolio mix aligned to concentration limits and risk appetite.
Summary: Front-line lender for large income-producing assets and for-sale projects, integrating market-grounded analytics with disciplined credit structures to support growth targets.
Scope & Responsibilities
Relationship development with sponsors, brokers, and co-lenders; opportunity screening against risk appetite.
End-to-end underwriting: NOI normalization, rollover schedules, tenant credit review, OpEx benchmarking, break-even analysis.
Construction: budget and GMP review, schedule validation, draw and retainage controls, third-party inspections.
Authored decision-ready credit packages; coordinated approvals, closing checklists, and post-close onboarding.
Active portfolio management: covenant tracking, borrowing-base/advance tests (where applicable), and variance reporting.
Representative Transactions
Income-Producing: Class A/B multifamily, last-mile industrial, medical/office repositionings, anchored retail.
For-Sale: Phased residential communities, townhome/condo projects, and mixed-use pads with staged releases.
Structures: Senior construction/bridge to mini-perm; selective recourse tiers and springing guarantees.
Risk Management & Governance
Applied LTV/DSCR/debt-yield thresholds by asset type and sponsor strength; exception rationale with compensating factors.
Sensitivity cases on rents, absorption, and cap rates; CECL/expected-loss lens for portfolio impacts.
Documentation and audit trails consistent with internal policy, FIRREA standards, and examiner expectations.
Outcomes
Balanced loan growth with credit discipline; improved cycle time and file quality.
Reduced post-approval rework via clearer intake criteria and standardized underwriting templates.
Summary: Supervised state member banks and holding companies with emphasis on CRE credit risk and capital markets/ALM. Led and participated in safety-and-soundness exams, translating supervisory expectations into actionable remediation while balancing safety, liquidity, and growth objectives.
Scope & Responsibilities
- Evaluated credit risk management: underwriting standards, administration, grading accuracy, problem-loan management, and ACL/CECL methodologies.
- Assessed capital markets & ALM: securities portfolio risk (AFS/HTM), IRRBB, derivatives/hedging use, liquidity profile, and contingency funding plans; reviewed ALCO governance and limit frameworks.
- Reviewed CRE concentrations (income-producing and construction/ADC), syndications/participations, covenant usage, appraisal review, and construction-draw controls.
- Assessed model risk management in line with SR 11-7: governance, validation, documentation, change control, and use-test.
- Conducted targeted file reviews (criticized/classified), performed sensitivity/stress analyses, and mapped findings to policy and limit adjustments.
- Authored exam reports and supervisory communications (e.g., MRAs/MRIAs) and tracked management remediation to closure.
Programs & Focus Areas
- Portfolio diagnostics on CRE exposure concentrations, pipeline mix, and exception governance.
- Liquidity & funding posture: wholesale reliance, brokered deposits, deposit stability analytics, and early-warning indicators.
- Stress testing across earnings/capital/liquidity with rate, NOI, and credit-migration scenarios; tie-backs to pricing, terms, and limits.
- Data and reporting quality for board/ALCO packages; third-party/vendor risk around data and models.
Risk Management & Governance
- Risk-appetite translation into LTV/DSCR/debt-yield bands, sector/MSA limits, and covenant sets with compensating-factor logic.
- Comprehensive documentation standards and audit trails aligned with interagency manuals, FIRREA, and model-risk guidance.
- Feedback loops from examination findings into policy redlines, underwriting templates, and monitoring triggers.
Outcomes
- Strengthened alignment between policy, limits, and frontline practices; clearer guardrails reduced exceptions and rework.
- Improved loan grading accuracy, CECL/ACL support, ALCO reporting quality, and liquidity/contingency frameworks.
- More predictable supervisory interactions and better exam readiness in subsequent cycles.
Advisory & Automation Services
These are the core service lines at LakeRock Capital, linking credit discipline to production velocity. Each engagement is anchored to interagency expectations (OCC/FDIC/FRB, SR 11-7, FIRREA) and delivers examiner-ready outputs (policies, models, memos, dashboards).
We are developing UnderwriteIQ™ to remove redundant keystrokes and compress cycle time, with success measured by faster clean approvals, fewer exceptions, and stronger risk-adjusted returns.
Focus: Credit risk modeling, faster/cleaner underwriting, and board-ready dashboards—aligned to OCC/FDIC/FRB expectations.
What We Do
Credit Risk Modeling & Analytics: PD/LGD/EAD proxies, CECL overlays, migration/cohort analysis, RAROC/ROE alignment, rate/NOI/exit-cap stress scenarios, concentration heatmaps (asset/MSA/sponsor/tenant).
Underwriting Enhancement: Intake triage, LTV/DSCR/debt-yield guardrails, compensating-factor logic, standardized credit memo templates, exception governance, QA/independent review; UnderwriteIQ™ assists with lease/OM/T-12 extraction and draft memoing.
Decision Dashboards: Portfolio stratification, pipeline-to-limit coverage, early-warning indicators, covenant tracking, watchlist triggers—delivered in Power BI/Tableau or your native environment with drill-downs to loan level.
Policy & Governance: SR 11-7 model documentation/validation, FIRREA appraisal interfaces, delegation matrices, concentration limits, and audit-trail controls.
Outputs
Risk diagnostics & policy redlines
Model inventory + documentation packets (SR 11-7)
Underwriting templates, playbooks, and “speed-to-yes” workflows
Dashboard suite: portfolio, pipeline, surveillance, and EWI
Examiner-ready files and workpapers
Focus: Market-grounded strategy, feasibility, and downside cases that translate into bankable decisions—linking asset-level underwriting to portfolio strategy and capital execution.
What We Do
Market Intelligence & Strategy: Define investment theses by submarket and corridor; map demand drivers, competing pipeline, zoning/entitlements, and public-incentive pathways; create go/no-go and priority scoring frameworks.
Asset-Level Underwriting & Feasibility: Normalize T-12s, rent rolls, and OpEx; build absorption curves and pricing programs; test Highest & Best Use, unit/tenant mix, and operating scenarios tied to LTV/DSCR/debt-yield guardrails.
Scenario & Sensitivity Modeling: Rate shocks, exit-cap expansion, lease-up delays, OpEx inflation, and capex overruns; break-even analysis and covenant implications (DSCR, DY) wired to structure recommendations.
Portfolio Optimization: Concentration heatmaps (asset/MSA/sponsor/tenant), hold/sell analyses, recycle-capital plans, and correlation insights to balance growth with risk limits.
Development & Construction Analytics: Precon budget validation, GMP/comparable checks, schedule risk, draw-curve modeling, interest-reserve sizing, contingency adequacy, and absorption alignment.
Capital & Exit Strategy: Structure design (senior/mezz/pref/JV), leverage bands, pricing targets (RAROC/ROE), refi risk, and exit pathways (stabilization sale, recap, mini-perm).
Executive Dashboards: IC/board-ready views of pipeline, feasibility KPIs, exposure, and early-warning indicators—delivered in Power BI/Tableau or your native environment with drill-downs to the loan/asset.
Governance & IC Support: Standardized IC memos, assumption logs, version control, and audit-ready workpapers; interfaces to appraisal/USPAP workflows and examiner expectations where needed.
AI-Enabled Efficiency (UnderwriteIQ™): Automated lease/OM/T-12 ingestion, comp harvesting, scenario templates, and draft investment briefs—reducing cycle time and variance without lowering standards.
Outputs
Investment briefs & IC memos (go/no-go with compensating-factor logic)
Feasibility studies, Highest & Best Use analyses, and downside cases
Structured financial models with scenario packs and break-even dashboards
Portfolio optimization plan and concentration/limit dashboards
Lender-ready materials for capital requests (sources/uses, terms, sensitivities)
Focus: Structure and place capital that survives diligence and market cycles—aligning leverage, terms, and covenants to risk, while moving from mandate to bankable term sheets with speed and discipline.
What We Do
Capital Strategy & Structure Design: Size leverage bands (LTV/LTC/DY), DSCR triggers, reserve/escrow programs, and recourse tiers; map structure to RAROC/ROE and exit/REFI risk.
Lender & Investor Mapping: Curate a targeted universe (banks, lifecos, agencies, CMBS, debt funds, mezz/pref/JV equity) by asset, market, and business plan; sequence outreach for competitive tension without process fatigue.
Deal Materials & Data Room: Build lender-ready teaser/CIM, sources & uses, model with scenarios, comps, lease abstracts, capex/budget, and diligence index; maintain a clean audit trail and version control.
Term Sheet Negotiation & Comparisons: Extract and normalize key economics (rate/credit spread, IO, amortization, fees), structure (recourse, carveouts, reserves), covenants, and cash management; run matrix comparisons with compensating-factor logic.
Construction & Development Capital: Validate GMP/budget, schedule, contingency and interest-reserve sizing; align draws, retainage, and third-party inspection protocols with lender requirements.
Intercreditor & Document Strategy: Coordinate senior–mezz/pref intercreditor/SNDA, carveouts, springing recourse, guarantor coverage, and assignment/participation mechanics with counsel.
Hedging & Rate Strategy: Evaluate caps/swaps, breakage risk, forward-start options, and covenant impacts; align hedge providers and term with sponsor objectives and lender rules.
Equity Solutions & Waterfalls: Pref/JV structures, promote design, catch-ups and hurdles; align governance (consents, major decisions, KPIs) with lender covenants and exit plan.
Closing & Workstreams Management: Own checklists, third parties (appraisal, ESA, PCA), legal comments, title/endorsements, estoppels/SNDAs, and path-to-close dashboards.
AI-Enabled Efficiency (UnderwriteIQ™): Auto-ingest term sheets and loan documents for side-by-side comparisons, flag covenant deltas, and standardize diligence packets to cut cycle time without lowering standards.
Governance & Compliance: KYC/AML readiness, sanctions checks, documentation controls; preserve examiner-friendly files that connect decisions to policy and risk appetite.
Outputs
Capital request package (teaser/CIM, model + scenario pack, sources & uses)
Curated lender/investor list with outreach plan and status dashboard
Term sheet comparison matrix with recommendations and redlines
Construction draw & interest-reserve model; hedge recommendation memo
Intercreditor/SNDA strategy notes and closing checklist
Final closing book and audit-ready documentation
Focus: Build and execute a repeatable investment program—clear mandate, disciplined underwriting, and operator-grade asset management—so capital is deployed deliberately and harvested on a predictable timeline.
What We Do
Mandate & Thesis Design: Define investment policy (IPS), target markets/corridors, asset types, risk bands (Core → Opp), leverage bands (LTV/LTC/DY), and return hurdles (IRR/EMx/ROE) with compensating-factor logic.
Deal Sourcing & Triage: Create scorecards for sponsor strength, business plan credibility, market depth, and downside resiliency; stand up a pipeline governance routine (intake → pre-screen → IC).
Underwriting & Feasibility: Normalize T-12s/rent rolls, build unit/tenant mix strategies, run scenario packs (rate, exit-cap, lease-up, OpEx inflation, capex variance), and tie results to pricing/terms.
Buy/Sell & Portfolio Strategy: Hold/sell tests, recycle-capital plans, concentration heatmaps (asset/MSA/sponsor/tenant), and pacing models that align deployment with risk appetite and liquidity.
Asset Management Playbooks: 100-day plans, NOI lift levers (revenue management, ops efficiency, expense controls), capex ROI governance, vendor KPIs, and quarterly business reviews.
Development & Construction Oversight (as applicable): Precon budget/GMP checks, schedule risk, draw-curve and interest-reserve modeling, contingency adequacy, and absorption alignment.
Operating Partner Selection: RFP process, reference and track-record validation, fee structures, incentives, and governance rights; establish reporting cadences and SLA metrics.
IC Governance & Reporting: Standardize IC memo templates, assumption logs, version control, exception policy, and audit trail; board/LP reporting packs with variance analysis and EWIs.
Exit & Capital Recycling: Broker RFPs, data room build, reverse diligence readiness, disposition timing windows, and tax-aware proceeds planning.
AI-Enabled Efficiency (UnderwriteIQ™): Auto-ingest OMs/leases/T-12s, comp harvesting, draft investment briefs and IC memos, and dashboard feeds to cut cycle time without lowering standards.
Outputs
Investment Policy Statement (IPS) and market/asset theses
Pipeline scorecards and IC decision framework
Underwriting models with scenario packs and break-even dashboards
Hold/sell analyses and portfolio optimization plan
Asset management playbook with KPIs and quarterly review templates
Partner selection dossier and operating agreements checklist
Disposition plan, data room index, and broker comparison matrix
Focus: Deploy regulator-aligned AI to cut cycle time and variance in underwriting, policy review, and document intelligence—without lowering standards. Built for banks, sponsors, and investors that need examiner-ready outputs and clear governance.
What We Do
Strategy & Governance: Define AI vision, scope, and guardrails; map to risk appetite, policy, and SR 11-7 model-risk expectations (roles, controls, validation, change management).
Use-Case Discovery & Prioritization: Rank pilots by impact/feasibility (underwriting, credit memo drafting, lease/OM/T-12 ingestion, appraisal/title abstraction, covenant monitoring, policy/exam GPTs, nCino workflow).
Pilot Design & Success Criteria: Set measurable targets (cycle time, defect rate, keystrokes removed, file completeness), sampling plans, and HITL checkpoints; build go/no-go gates.
Data & Document Intake: Connect to SharePoint/OneDrive, Box/Google Drive, SFTP/data warehouses; normalize PDFs/Excel; create data lineage and retention rules (GLBA/PII aware).
RAG & Model Architecture: Private retrieval over your documents; prompt libraries, tool use, and guardrails; output schemas aligned to credit memo and policy templates.
Workflow Integration: Embed into nCino/Salesforce and bank LOS/credit systems; push/pull from Jack Henry/FIS/Temenos where applicable; auto-populate fields and attachments.
Controls, Testing & Validation: Red-team scenarios, UAT scripts, challenger models, benchmark tasks; track accuracy, bias, stability, and drift with auditable evidence.
Security & Hosting: SaaS (LakeRock-managed), Private VPC (your cloud), or on-prem; SSO (SAML/OIDC), encryption at rest/in transit, role-based access, immutable audit logs.
Change Management & Training: Playbooks, quick-ref guides, and train-the-trainer; align delegation matrices and exception policies to AI-augmented workflows.
Operating Model & Scaling: Define SLAs, support tiers, monitoring dashboards, and incident response; handoff to IT/risk with a runbook and cost/benefit cadence.
Outputs
AI Program Charter and Pilot Scope with success metrics
Model Cards, data maps, and SR 11-7 documentation bundle (governance, validation, change control)
Prompt libraries, output schemas, and workflow diagrams (credit memo, policy review, document abstraction)
Integration specs for nCino/Salesforce and document repositories
UAT/QA packs, red-team results, performance dashboards, and audit logs
Implementation runbook, training kit, and go/no-go recommendation
Regulatory & Technical Familiarity
Frameworks & Standards
- OCC/FDIC/FRB exam protocols,
- Basel III/IV,
- SR 11-7 model risk,
- FIRREA,
- USPAP interfaces,
- credit grading,
- policy governance,
- documentation retention.
Tooling & Data:
- nCino/Salesforce workflows,
- Generative AI: ChatGPT, Claude
- Other AI: MidJourney, Zappier
- SharePoint/M365,
- Box/GDrive,
- data warehouse/SFTP,
- doc intelligence pipelines.
Leadership
In an era where cycles turn faster, regulators demand more, and credit portfolios are under constant pressure, the CRO and CLO carry the responsibility of protecting both capital and credibility.
Drawing on decades of regulatory, banking, and advisory experience, Derek distills five operating philosophies that define resilient leadership in commercial real estate finance.
Growth is only sustainable if risk is visible early. Every expansion should be paired with stress testing and covenant surveillance that reveal vulnerabilities before the market does.
For CROs and CLOs, influence with regulators and boards is as valuable as portfolio yield. Files must be examiner-grade, defensible, and audit-ready at all times.
The strongest portfolios aren’t the most aggressive or conservative; they are the most balanced. Diversification is resilience, not retreat.
AI is not a shortcut - it’s a safeguard. When built on policy, automation strengthens underwriting consistency, reduces errors, and delivers audit-ready outputs faster.
Saying “no” credibly is as powerful as approving the right deal. True leadership preserves capital and credibility, even under pressure.