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

disclosure

CFPB Releases HMDA Public Data Tables

By | June 21, 2021

The CFPB has released the public disclosures for HMDA data submitted for calendar year 2020. HMDA reporting institutions can go to the FFIEC HMDA Data Publication section of the CFPB website and download their disclosure tables. As a reminder, the tables are no longer required to be made a part of your CRA Public File. […]

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When the Tide is Against You

By | May 13, 2021

Over the past several months, the banking industry has experienced tremendous loan origination volume. While increased loan production is a good thing, it is important for Compliance Managers to stay cognizant of rising risks. Pressure, whether from peers or self-imposed, to push loans through leads to a breakdown in controls that are caused from procedural […]

regulations book

HMDA – Field Reporting Exemption under EGRRCPA – When does a Bank Lose this Exemption?

By | April 26, 2021

Under the Economic Growth, Regulatory Relief and Consumer Protection Act (EGRRPA), many banks were exempt from reporting all fields on the HMDA LAR as they had originated fewer than 500 closed-end HMDA Reportable loans or fewer than 500 open-end HMDA Reportable loans during the prior calendar year. With the dramatic upturn in production during the […]

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The Great Debate — Is This a Finance Charge?

By | April 13, 2021

If only there was a simple answer! Unfortunately, this seemingly simple question can be endlessly debated due to the complexity of Regulation Z. §1026.4(a) states that a finance charge is the cost of consumer credit as a dollar amount. It includes any charge payable directly or indirectly by the consumer and imposed directly or indirectly […]

Fair Lending

Meet your Community’s Credit Needs for Fair Lending – Utilizing Regulation B’s Special Purpose Credit Program

By | April 7, 2021

“What are you doing to ensure diversity, equity and inclusion (DEI)?”  That question routinely comes up during conference calls among us, clients, and regulatory agencies. Businesses, educational institutions, and non-profit organizations all are focusing on DEI.  Financial institutions are no exception. In fact, regulatory agencies emphasize the importance of DEI in written communications about the Fair […]

community reinvestment act

CRA Public File Reminder

By | March 25, 2021

April 1st is known as April Fools’ day and a time to play tricks and pranks. But did you know on April 1, 1748, the Ruins of Pompeii were rediscovered by Spaniard Rocque Joaquin de Alcubierre? Guess it is time to rediscover the CRA Public File and make sure nothing ancient is inside! By now […]

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

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