Regulation O Reviews

stack of files with magnifying glass on top showing data review

Measuring your compliance with Regulation O and ensuring that you’re effectively managing the risks associated with insider loans

We guide you on the best ways to meet the credit needs of insiders while staying within the boundaries of Regulation O.

Banks routinely extend credit to board members and other insiders. Still, it can be risky unless you thoroughly understand and adhere to Regulation O. There are issues of transparency to consider and the potential for conflicts of interest and favoritism.

Conducting Reg O reviews is a standard part of our services, and TCA consultants understand the regulation’s impact on your lending and overall risk.

Our team shows you the best way to comply with Reg O while supporting the needs of creditworthy insiders and avoiding financial penalties and reputational harm.

We root out any issues that may raise red flags with examiners and prepare you for your exam by:

  • Looking at your written policies and procedures to be sure they define who’s considered an insider and reviewing your guidelines for lending to such prospects: lending limits, loan terms, the approval process, and so forth.
  • Evaluating your documentation to ensure that your record-keeping is satisfactory and includes accurate loan files, agreements, disclosures, etc.
  • Examining transactions to verify that insiders aren’t receiving preferential treatment on loan terms, interest rates, and repayment plans.
  • Gauging the adequacy of internal controls and audit processes and whether they reflect your policies.
  • Assessing whether your board of directors and staff thoroughly understand Reg O.

By the end of our review, you’ll gain a complete picture of your Reg O compliance strengths and weaknesses, and we’ll make recommendations about enhancing your program.

By working with TCA, you’ll find A Better Way to control Reg O risk and protect your bank when extending credit to insiders.

Key deliverables include:

  • Identifying compliance gaps and recommending solutions
  • Verifying whether the credit extended to insiders falls within Reg O’s lending limits
  • Uncovering any evidence that insiders have improperly used their positions for personal gain
  • Determining whether your insider lending processes are transparent and protect the interests of your bank

Additional Compliance Topics

update, upgrade, to update-1672349.jpg

Regulatory Updates – Fourth Quarter 2022

By | February 21, 2023

Below is a link to the Regulatory Updates as of the end of Q4. TCA provides A Better Way for you to track Compliance updates and keep your organization on track. You can download the updates in a PDF form here.As always, TCA is here to help with A Better Way to answer all your […]

news, information, broadcast-7246477.jpg

HMDA News and Census Tract Updates

By , | February 3, 2023

Breaking News!! This week the OCC, FRB and FDIC announced their stance on HMDA reporting for institutions thrown back into HMDA reporting due to the recent Court decision to roll back the closed-end mortgage reporting threshold from 100 back to 25. All three regulators are taking the same stance as the CFPB and have stated […]

community reinvestment act

CRA Asset-size Thresholds Announced for 2023

By | January 13, 2023

The annual CRA asset-size thresholds for covered financial institutions were announced December 19, 2022 by the FDIC and FRB and on December 28 by the OCC applicable for 2023. The cutoff adjustments are based on the change in the CPI (Consumer Price Index) for each 12-month period ending in November, rounded to the nearest million. […]

mortgage loan disclosure

HMDA and HPML Thresholds Bumped Up for 2023

By | January 10, 2023

On December 28, 2022, the Consumer Financial Protection Bureau (CFPB) amended the Home Mortgage Disclosure Act (Regulation C) and the Truth in Lending Act (Regulation Z), adjusting the asset-size exemption thresholds for banks, savings associations, and credit unions. Like the CRA thresholds, the adjustments are pegged to the annual percentage increase in the Consumer Price […]

regulations block as piece of a puzzle

New Threshold Amounts for 2023 under Regulation Z CARD Act, HOEPA and QM Sections

By | January 6, 2023

Based on the 8.9% increase in the Consumer Price Index (CPI-W) in effect on June 1, 2022, the Consumer Financial Protection Bureau (CFPB) released a number of new thresholds which go into effect on January 1, 2023. They include: Additionally, these changes affected the HOEPA threshold amounts found under 1026.32 based on the 8.3% increase […]

home mortgage application

HMDA Reporting Threshold Changes Due to Court Ruling

By | December 20, 2022

On April 16, 2020, the CFPB released a final rule affecting the thresholds for HMDA reporting. Effective July 1, 2020 the number of closed-end loans originated to be considered a “financial institution” was increased from 25 to 100 for each of the two preceding years for both depository and non-depository institutions. On September 23, 2022, […]

Do You Need Compliance Help?

We’re here to review your current compliance strategy and help you find A Better Way to manage risk.

Phone

800-934-REGS

Email for Non-Confidential Information Only

[email protected]

Office Location

2021 Midwest Road, Suite 200,
Oak Brook, IL 60523

Endorsed By