Commercial/Residential Regulation Information

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Question:

My job has been to work on residential compliance. My boss has just taken over the servicing side for commercial loans.I have never worked with commercial loans before now. Where would I start? I understand that some of the Reg's encompass residential and commercial. What fees are allowed? Where would those do's and don'ts be found?

Answer:

Allowable fees for commercial loans are generally as negotiated by contract subject to any state laws. Federal regulations related to commercial loans are:

UCC, Reg B, Reg C (HMDA), Reg E as it relates to auto debit of payments on loans to individuals, Reg O, Reg U, Reg W, Reg BB (CRA), Flood, Appraisal rules, BSA/CIP. Commercial should have procedures in place to address these and other requirements.

There can be additional regulations required by state law that can require other disclosures.

First published on BankersOnline.com 6/6/11