Jack, as most of us experience, Commercial divisions aren’t accustomed to dealing with consumer regulations. Do you have a list or can you comment on the consumer Regs a commercial division might need to comply with? Obviously, Reg B, Flood, HMDA, BSA/OFAC, but if they have retail branches that accept deposits and international operations this could expand into the deposit-related regs and others (i.e. FCRA, Privacy). And then there are those interesting “accomodation loan” situations that introduce a host of others… ❓
Thanks and congratulations on this site – looks great!
Thanks for being part of the Forum. I hope you come back often, both with questions and with answers for those seeking guidance.
I completly agree with your comments on commerical lending, the area is ripe for compliance violations. You asked for a list of the consumer regulations a commercial division might need to comply with? Periodically I conduct a webinar that deals directly with this issue. You note that Regulation B, Flood, HMDA, BSA/OFAC all apply. But even Regulation Z and RESPA may apply to certain loans made in the commercial department. Those coverage rules are the primary focus of the webinar.
The webinar is entitled Compliance for Commerical Lenders. I conducted the program on March 31, 2011 (how timely) for the state banking associations. Contact your state association to listen to the archived copy of the program. The same program program is tentatively scheduled for July 19th with bankersonline.com. With both options you can train an unlimited number of commercial lenders for one price. The July program includes a Question and Answer session, so your lender’s questions can be asked and answered.