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Threshold for Regulation Z Coverage (Non-RE Loans)

Should non-RE loans that exceed the dollar threshold for Regulation Z coverage still be considered consumer loans as far as coding and reporting? We have a difference of opinion. One side believes the Reg Z exemption essentially changes the loan into a commercial loan in every way. The other thinks that the disclosures in the documentation is where the exemption is primarily seen and the loan should be coded and reported exactly like any other loan of its type that is under the threshold. Any clarification would be appreciated.

by Richard Insley:

Coding and reporting of anything must follow the law/reg that requires the report. Reg. Z's distinction between consumer and commercial loans has no direct relationship to other sets of rules unless the other rules incorporate it by reference. If a reporting rule sets no standard and references no external standard, then you follow commercially reasonable practices. Reg. Z's definitions have been in place for 50 years, and would certainly be one consideration--particularly if banking supervisors consider them to be relevant.


by Randy Carey:

If you are referring to the call report. Read the instructions for schedule RC-C 6.c and 6.d, you will see no mention of thresholds, only " loans to individuals for household, family, and other personal expenditures". If this coding pushes your call reporting, you want to make sure it is correct.

First published on 02/16/2020

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