United States

Exam procedures updated for TRID rules


Three of the prudential regulators have updated their exam procedures to reflect the TILA/RESPA Integrated Disclosure (TRID) Rules that become effective Aug. 1, 2015. 

The Consumer Financial Protection Bureau has updated the Supervision and Examination Manual. A list of recent updates, including those for TRID, is available here.

The Task Force on Consumer Compliance of the Federal Financial Institutions Examination Council has developed interagency examination procedures for the TRID Rules. As a result, the Office of the Comptroller of the Currency issued Bulletin 2015-27 announcing it is in the process of incorporating the interagency procedures into the “Truth in Lending Act” and “Real Estate Settlement Procedures Act” booklets of the Comptroller's Handbook. The Board of Governors of the Federal Reserve System issued Consumer Affairs Letter CA 15-3. This contained its revised procedures reflecting the amendments to Regulation Z and Regulation X, as well as, a Summary of Updates to Examination Procedures for Regulation Z and Regulation X which provides a guide to the changes.

As of the date of writing this article, no exam procedure updates for TRID have been announced by the Federal Deposit Insurance Corporation or the National Credit Union Administration.

Additionally, the OCC updated the Comptroller's Handbook to include guidance pertaining to the mortgage servicing rules that became effective January of 2014. Thus, the booklet is now complete as it contains both the mortgage servicing rules effective January 2014 and the TRID Rules that will be become effective August 2015.