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#1664356 - 02/13/12 08:22 PM Commercial vs personal investment loans
Marmaduchess Offline
100 Club
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: 20,654
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.
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

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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: 10,056
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.
...gone fishing.

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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.
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy

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