Measuring your compliance with Regulation O and ensuring that you’re effectively managing the risks associated with insider loans
We guide you on the best ways to meet the credit needs of insiders while staying within the boundaries of Regulation O.
Banks routinely extend credit to board members and other insiders. Still, it can be risky unless you thoroughly understand and adhere to Regulation O. There are issues of transparency to consider and the potential for conflicts of interest and favoritism.
Conducting Reg O reviews is a standard part of our services, and TCA consultants understand the regulation’s impact on your lending and overall risk.
Our team shows you the best way to comply with Reg O while supporting the needs of creditworthy insiders and avoiding financial penalties and reputational harm.
We root out any issues that may raise red flags with examiners and prepare you for your exam by:
- Looking at your written policies and procedures to be sure they define who’s considered an insider and reviewing your guidelines for lending to such prospects: lending limits, loan terms, the approval process, and so forth.
- Evaluating your documentation to ensure that your record-keeping is satisfactory and includes accurate loan files, agreements, disclosures, etc.
- Examining transactions to verify that insiders aren’t receiving preferential treatment on loan terms, interest rates, and repayment plans.
- Gauging the adequacy of internal controls and audit processes and whether they reflect your policies.
- Assessing whether your board of directors and staff thoroughly understand Reg O.
By the end of our review, you’ll gain a complete picture of your Reg O compliance strengths and weaknesses, and we’ll make recommendations about enhancing your program.
By working with TCA, you’ll find A Better Way to control Reg O risk and protect your bank when extending credit to insiders.
Key deliverables include:
- Identifying compliance gaps and recommending solutions
- Verifying whether the credit extended to insiders falls within Reg O’s lending limits
- Uncovering any evidence that insiders have improperly used their positions for personal gain
- Determining whether your insider lending processes are transparent and protect the interests of your bank
Additional Compliance Topics
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Regulatory Updates – Second Quarter 2023
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“ARM” Yourself for Volume Increase and Avoid Common Compliance Pitfalls
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FDIC Doubles Down and the OCC Jumps in On the Overdraft Discussion
The history of overdraft guidance goes back to 2005 with the Joint Guidance on Overdraft Protection Programs. The FDIC followed up with the Overdraft Payment Programs and Consumer Protection Final Overdraft Payment Supervisory Guidance in 2010 and the FDIC Overdraft Payment Program Supervisory Guidance FAQ in 2011. In 2019, the FDIC provided more information relating …
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FDIC Name Change – Updated, Again
On August 8, 2022 in the Federal Register (and a correction on August 12) the FDIC reported they had renamed the Consumer Response Center to the “National Center for Consumer and Depositor Assistance”. This Division is referenced in the Fair Housing regulation at 12 CFR 338 and in the Consumer Protection in Sales of Insurance …
CFPB Bulletin – HMDA Address Issues
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