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Today is: May 24, 2018  
 

Compliance Companion®
Standard Procedures Manuals (SPM)
 

Consumer Lending Compliance April 2018


Standard Procedures Manual #1 reviews all of the major federal and California laws and regulations relevant to consumer lending compliance. The Manual is organized around the life cycle of a consumer credit transaction, beginning with advertising and marketing, through processing an application, loan closing, loan servicing, and changes after closing – whether with the borrower’s consent or due to the consumer’s default. This approach allows for a review of each regulation at the stage in the life cycle of a consumer loan when the regulation is relevant.

Note that this Manual does not address mortgage lending compliance. Refer to BCG Standard Procedures Manual #8, Mortgage Lending Compliance, for the compliance requirements regarding mortgage lending.

This Manual addresses the following stages of a consumer loan:

  • Introduction and coverage of the major regulations
  • Marketing, advertising and solicitations
  • Distributing the application
  • Receiving and processing the application
  • Loan closing
  • Contract and promissory note issues
  • Loan servicing
  • Subsequent changes
  • Creditor’s remedies on default
  • Penalties and liability

The Manual has been updated to include a summary of the new Regulation Z requirements regarding hybrid prepaid-credit cards pursuant to the CFPB’s Prepaid Rule, which will become effective April 1, 2019.

The Manual also includes separate discussions regarding any unique compliance issues associated with the following types of consumer loan products:

  • Personal unsecured loans and lines of credit
  • Overdraft lines of credit
  • Credit cards
  • Loans secured by certificates of deposit
  • Loans secured by stock
  • Automobile lending (direct and indirect)
  • Automobile leasing
  • Manufactured homes, mobile homes and recreational vehicles

The main text of the Manual is 650 pages, plus 43 pages of appendices.

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