If TILA disclosures are provided in a loan to a business entity and the APR is understated - is this a violation of regulation Z although loans to business entities are exempt from the coverage of Regulation Z?
Should non-RE loans that exceed the dollar threshold for Regulation Z coverage still be considered consumer loans as far as coding and reporting? We have a difference of opinion. One side believes the Reg Z exemption essentially changes the loan into a commercial loan in every way. The other thinks that the disclosures in the documentation is where the exemption is primarily seen and the loan should be coded and reported exactly like any other loan of its type that is under the threshold. Any clarification would be appreciated.
Our bank is an Intermediate Small Bank under the current CRA rule, with an asset size of $750 million. Will we still be treated differently from large banks under the proposed rule?
Does CAN-SPAM apply to those emails sent by platform employees to let their preferred customers know of new rates, etc.?
Our bank has several assessment areas that include partial counties. The counties are large and the bank does not feel it can serve the entire county. Will we be able to continue with this practice under the proposed CRA rule?