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#1664356 - 02/13/12 08:22 PM Commercial vs personal investment loans
Marmaduchess Offline
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Marmaduchess
Joined: Oct 2009
Posts: 169
Oregon Coast
What is the difference between commercial loans and personal (consumer) investment loans as far as compliance with consumer/commercial regs. We have a hard time telling the difference and I think we may be coding some of these loans the wrong way on our system.

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Lending Compliance
#1664417 - 02/13/12 09:05 PM Re: Commercial vs personal investment loans Marmaduchess
RR Joker Offline
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RR Joker
Joined: Nov 2002
Posts: 20,653
The Swamp
Generally, it makes the difference on whether Z applies or not. The term "investment' is meaningless, IMHO...the LO's need to describe what TYPE of investment it is before you can determine whether it's business or personal.
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My opinion only. Not legal advice.

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#1664458 - 02/13/12 09:51 PM Re: Commercial vs personal investment loans Marmaduchess
Richard Insley Offline
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Richard Insley
Joined: Oct 2000
Posts: 10,035
Toano, VA
"Commercial loan" isn't a rock solid term throughout the industry either. Loans with corporations or other business entities as obligors are not consumer loans. Loans to individuals must be examined carefully--beginning with the applicant's purpose statement.

You may have state laws & regs. dealing with business loans, but normally they are free from consumer protection regulations.
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#1664514 - 02/13/12 11:29 PM Re: Commercial vs personal investment loans Marmaduchess
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
The Reg Z commentary provides good examples to walk you through it. When I was in commercial lending (and before this was all online) I carried the little commentary booklet around, all highlighted.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
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