Throughout all the rules and regulations "residential mortgage" is clearly defined. I cannot locate anywhere that "personal loan" is defined. Recently an auditor was reviewing the Bank's subsequent ARM notices under 3- CRR- NY 33. I have always glossed over this section when conducting a Compliance Review as the Bank doesn't offer adjustable rate personal loans. Luckily our notices comply with TILA so in the end there were no issues but is the Auditor correct? The State came in a few years back, they asked us the question regarding personal loans so we advised we do not offer adjustable rate personal loans and that was that. Unless they did review our notices and also saw we comply with TILA and didn't mention anything because of it.