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You don't know X about Z - 2015
Mary Beth Guard Andy Zavoina and John Burnett Recorded on November 17, 2015
The old adage "What you don't know can hurt you" holds true, even in the compliance context. Failure to get it right when it comes to Reg Z coverage, including the overall reg itself, as well as the variations in coverage triggers and exemptions for particular provisions within the reg, can cost your institution time and money.
There are dangers in over-complying. If you think it's a good idea to go ahead and use Reg Z disclosures on loans that are not subject to Reg Z, we will explain why it's not. If you think there is no harm in treating an application/loan as covered by Reg Z when it really isn't, we will sketch out repercussions to consider that will put the harm in perspective.
When you aren't sure whether a loan is subject to Regulation Z, it may seem like a good idea to take the "safe" choice and just provide the disclosures. That may have been the better choice in the past, but having a true understanding of what "consumer credit" comprises will serve your bank better, because the "conservative" approach of disclosing when in doubt is not the optimal choice for the bank's bottom line.
Assuming any loan secured by rental property is a business loan can have disastrous consequences. Conversely, if you wrongly regard certain types of rental property-related loan apps as being subject to Regulation Z, you will jump through hoops there is no need to jump through.
To avoid over-compliance, you need to know:
How the "primary" purpose test works
What is business credit
What is commercial credit
What is agricultural credit
What is organizational credit
What exemptions exist from each of the different sets of requirements under Reg Z
The three factors to look at when rental property is involved
How to tell if a trust as an applicant is exempt
The different scopes of coverage for different parts of Reg Z
And much more!
This program will make you a Reg Z coverage master!
Mary Beth Guard
Mary Beth Guard currently serves as Executive Editor of BankersOnline.com, CEO of Glia Group, Inc. and Executive Editor of BankingQuestions.com. Since graduating from law school in 1980, Mary Beth has focused her work almost exclusively on the banking industry. Previously, Mary Beth served as EVP/General Counsel and COO for the Oklahoma Bankers Association, EVP of Specialized Services for Thomson Financial Publishing, and General Counsel for the Oklahoma State Banking Department. Mary Beth is on the advisory board for Bankers' Hotline. She has presented training programs for virtually every major national financial industry association, as well as more than a dozen state bankers associations and a host of other organizations. In addition, Mary Beth has written more than a thousand banking-related articles and is a BOL Guru.
Mr. Andy Zavoina, CRCM, is an Executive Vice President with the Glia Group, Inc., best known for its involvement with BankersOnline.com. He joined Glia and BOL in 2003.
Mr. Zavoina has been in finance and banking for over 39 years. Over 20 years were with a two-bank holding company that had $534 million in assets, 89 branches spanning Texas and nearly 500 ATMs. He has done loan workouts, has been a consumer, commercial and real estate lender and managed those departments, as well as being his banks first Webmaster. He was responsible for compliance -management, -auditing, and -training for both banks.
Mr. Zavoina is a recipient of the American Bankers Association’s Distinguished Service Award for his involvement and accomplishments in the field of regulatory compliance management. He is a past Chairman of the ABA’s Compliance Executive Committee, the Editorial Advisory Board for the ABA Compliance Magazine and served as a member of the ABA’s Compliance School Board. He is a BankersOnline Guru. He also served on the Texas Bankers Association's Compliance Committee. He is a graduate of the ABA National Commercial Lending School, National Compliance and National Graduate Compliance School and is a Certified Regulatory Compliance Manager with the Institute of Certified Bankers. He has written articles and lectured on compliance, the use of the internet and technology as a tool, as well as compliance in cyberspace to local, state and national associations across the U.S. and teaches basic compliance and compliance management.
You can reach Andy on the Internet by using his e-mail address, email@example.com, or visiting http://www.bankersonline.com.
John Burnett is a 1979 alumnus of the ABA National Compliance School, and served on its faculty for several years. He graduated with honors with the Class of 1990 from ABA's Stonier Graduate School of Banking, and is also a graduate of the BAIs and the Massachusetts Banker Associations Schools of Banking.John began his banking career in high school when he started as a teller at a $15 million bank that didn't have account numbers for its checking accounts (he says they actually filed by signature!) He joined Cape Cod Bank and Trust Company in 1971 and assumed the position of Compliance Officer in 1976. He also served as corporate secretary and secretary of CCBT's Board of Directors, as well as Clerk of the bank's holding company. John joined Glia Group, Inc. and the BankersOnline.com team in June, 2004. He is a frequent presenter of BOL Learning Connect webinars, and at BOL Conferences events.He was a member of the Massachusetts Bankers Association Legal and Regulatory Compliance Committee, and a former member of the American Bankers Association Compliance Executive Committee and NCS/NGCS Advisory Board. He served on ABA's Truth in Savings Task Force as Regulation DD was being written, and has served on several ABA and Massachusetts Bankers seminar panels.