Skip to content
BOL Conferences
Thread Options
#993663 - 07/11/08 05:38 PM Reg Z reimbursement/disclosure required?
MT Pockets Offline
100 Club
Joined: Oct 2004
Posts: 238
Up North
During a recent loan compliance audit I found a loan that was originated as a commercial loan secured by ag products but should be a consumer purpose loan (pay personal medical bills). Should I recommend reimbursement and disclose the loan under Reg Z now (6 months into an 11 month term)? What is required by Reg Z?
_________________________
If you keep doing what you've always done, you'll get what you always got.

Return to Top
Lending Compliance
#993685 - 07/11/08 05:52 PM Re: Reg Z reimbursement/disclosure required? MT Pockets
Richard Insley Offline
10K Club
Richard Insley
Joined: Oct 2000
Posts: 10,179
Toano, VA
Originally Posted By: MT Pockets
What is required by Reg Z?

Nothing. The time to determine Reg. Z's coverage and provide a useful disclosure has passed. Now, it's a matter of managing the risk that this borrower might sue your bank alleging violations of the TIL Act. The statute of limitations for a TIL action is 12 months & you're half way there w/o litigation. I'd let sleeping dogs lie. Review procedures and training and fix anything that would allow this situation to arise again.
_________________________
...gone fishing.

Return to Top
#993721 - 07/11/08 06:23 PM Re: Reg Z reimbursement/disclosure required? Richard Insley
MT Pockets Offline
100 Club
Joined: Oct 2004
Posts: 238
Up North
Whew, that sounds good to me. This has been the only loan found during the audit that was misclassified and was discussed with the lender. Thank you for your help.
_________________________
If you keep doing what you've always done, you'll get what you always got.

Return to Top

Moderator:  Andy_Z