Commercial Loans and the FCRA

By Victoria E. Stephen The Fair Credit Reporting Act, or FCRA for short, basically regulates the furnishing and collecting of credit information and imposes certain disclosure requirements in connection with accessing credit reports. The FCRA itself is a statute and only a few parts ...Read More

Compliance Q&A: Reg O

Question: Would the bank be violating Reg. O if it offered a higher Money Market rate for just shareholders? Answer: There is not a direct prohibition in Reg. O, since it primarily governs credit and not deposit accounts, like money market accounts. However, many banks have ...Read More

Question: I have a loan officer who issued a loan estimate that predates the application date by 1 day. While I don’t believe this to be best practice, I’m not certain whether it’s also a violation of regulation. Can someone please confirm? Answer: Assuming the required ...Read More

The Why and How of Environmental Risk

By John Berteau, Associate General Counsel For banks, environmental risk management addresses concerns about the present by looking into the past and gazing into the future. A good environmental risk policy looks to the past to identify existing environmental liabilities before making loans secured ...Read More