All of the regulations reviewed in a compliance examination cover consumer lending, but many of those regulations also impact commercial lending. Determining exactly which requirements impact commercial loans is a challenge. We are pleased to present this program to help commercial lenders understand which compliance requirements impact their department.
This two-hour program identifies the major compliance regulations that apply to commercial transactions and reviews particular issues from each of those regulations that cause problems for commercial lenders.
Many examiners find the commercial lending area is fertile for compliance violations because of confusion regarding which requirements apply to commercial loans. Those violations may result in penalties or expensive litigation. This program:
- Identifies problem areas;
- Provides suggestions for avoiding and curing the problems; and
- Covers training and auditing concerns.
Participants receive a detailed manual that serves as a valuable resource long after the conclusion of the program.
Upon completion of the program participants understand the importance of establishing and documenting the loan purpose and how the following laws and regulations impact the commercial lending process:
- Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) Provisions - Filing CTRs, CTR exemptions, and OFAC;
- USA PATRIOT Act - Customer Information Program (CIP), Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), and Beneficial Ownership;
- Suspicious Activity Reporting (SAR) Provisions;
- Unlawful Internet Gambling Enforcement Act (UIGEA) - Regulation GG;
- Equal Credit Opportunity Act (ECOA) - Regulation B - Discrimination prohibition, appraisal rules, application disclosures, spousal signature rules, intent to be a joint applicant, and adverse action notice requirements;
- Fair Housing Act (FHA) - Discrimination prohibition;
- Home Mortgage Loan Disclosure Act (HMDA) - Regulation C - Data collection and reporting requirements and revisions to Regulation C;
- Flood Disaster Protection Act (FDPA) - Required disclosures and insurance requirements, and recent changes;
- Fair Credit Reporting Act (FCRA & FRB) - Regulations V - Requesting and using credit bureau reports, identity theft provisions and adverse action notice requirements;
- Truth in Lending Act/Regulation Z - Coverage rules, restrictions and required disclosures, Special rules (1026.12(a) and (b)) for business-purpose credit cards;
- Real Estate Settlement Procedures Act/Regulation X - Coverage rules, restrictions and required disclosures;
- Real Estate Appraisal Interagency Guidance;
- Servicemember Civil Relief Act (SCRA);
- Military Lending Act;
- Insider Credit - Regulation O;
- Securities Lending - Regulation U;
- Right to Financial Privacy Act (RFPA) and Regulation S (Reimbursement for partnerships with 5 or fewer partners);
- Community Reinvestment Act (CRA) - Regulation BB - Data collection and reporting requirements;
- Bank Bribery Act Implications;
- Unfair, Deceptive or Abusive Acts or Practices;
- Americans with Disabilities Act; and
- Other rules and regulations that impact commercial loans.
The program is designed for Commercial Loan Officers, Compliance Officers, Auditors, and those responsible for documenting commercial loans.