Would there be a regulatory issue for investment loans for 1-4 Family, condo and coop loans not being originated by the Commercial Lending area?

How about these loans with individual applicants to purchase investment properties?

Thanks.

That is a bank policy issue not regulatory issue. If an individual is buying and financing non-owner occupied 1-4 family properties, the lender just needs to be diligent on making sure the property is going to cash flow and that the borrower's other projects support this debt as well.

The area generating the loan in the bank is moot. Borrowers, purposes and such are your concern. The fact that a truck loan was made by a commercial lender for the borrowers son as a graduation gift doesn't make it a business loan or exempt from Reg Z as an example.

Fair housing and Reg B rules apply to consumer and commercial loans, but you can avoid Reg Z issues, per 1026.3, "Credit extended to acquire, improve, or maintain rental property (regardless of the number of housing units) that is not owner-occupied is deemed to be for business purposes."