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.

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.

"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.

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.