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The Bank, which is chartered in New Jersey, is making a commercial loan to a limited liability company. When it obtained the company’s Certificate of Formation, it noticed that one of its own directors is listed as “Registered Agent.” The director does not have an ownership interest in the company. Would the requirements of Regulation O be applicable to the loan because the director is the registered agent of the company?
The Bank will be having a FDIC Compliance and CRA review. In the CRA Public File, is it required to include a notice that the HMDA Disclosure Statement may be obtained on the CFPB’s Website? The Bank currently has the HMDA disclosure statements from the FFIEC for the previous two calendar years in the file.