Regulation O Reviews

stack of files with magnifying glass on top showing data review

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

hdma

Do you Remember? HMDA – Reporting Open-End Lines of Credit

By | August 25, 2022

It’s time for a trip into the Way-Back Machine, all the way back to April 16, 2020, when the Consumer Financial Protection Bureau (CFPB) issued a final rule amending Regulation C. This amendment permanently raised the closed-end coverage threshold from 25 to 100 closed-end mortgage loans in each of the two preceding calendar years. The […]

mortgage application

HMDA and HPML Thresholds Bumped Up for 2022

By | December 30, 2021

The Consumer Financial Protection Bureau (CFPB) amended the Home Mortgage Disclosure Act (Regulation C) and the Truth in Lending Act (Regulation Z), adjusting the asset-size exemption thresholds for banks, savings associations, and credit unions. Like the CRA thresholds, the adjustments are pegged to the annual percentage increase in the Consumer Price Index for Urban Wage […]

disclosure

CFPB Releases HMDA Public Data Tables

By | June 21, 2021

The CFPB has released the public disclosures for HMDA data submitted for calendar year 2020. HMDA reporting institutions can go to the FFIEC HMDA Data Publication section of the CFPB website and download their disclosure tables. As a reminder, the tables are no longer required to be made a part of your CRA Public File. […]

regulations book

HMDA – Field Reporting Exemption under EGRRCPA – When does a Bank Lose this Exemption?

By | April 26, 2021

Under the Economic Growth, Regulatory Relief and Consumer Protection Act (EGRRPA), many banks were exempt from reporting all fields on the HMDA LAR as they had originated fewer than 500 closed-end HMDA Reportable loans or fewer than 500 open-end HMDA Reportable loans during the prior calendar year. With the dramatic upturn in production during the […]

currency transaction reports

Currency Transaction Reports: Fin-2020-R001

By | April 9, 2020
image of offsite review

Considerations for Managing an Offsite Review

By | April 6, 2020

They say change is constant and that’s never been truer than now. In our current reality of sheltering in place and social distancing, each day presents new challenges and opportunities. TCA’s article “COVID-19 Business Impact: What Can You Do to Help?” focuses on how institutions can help customers during the current pandemic, and on the […]

Do You Need Compliance Help?

We’re here to review your current compliance strategy and help you find A Better Way to manage risk.

Phone

800-934-REGS

Email for Non-Confidential Information Only

[email protected]

Office Location

2021 Midwest Road, Suite 200,
Oak Brook, IL 60523

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