As of May 1, the Task Force on Consumer Compliance of the Federal Financial Institutions Examination Council developed interagency examination procedures for:

  • Truth in Lending Act (TILA), implemented by Regulation Z; and
  • Real Estate Settlement Procedures Act (RESPA), implemented by Regulation X.

These procedures reflect Consumer Financial Protection Bureau amendments to Regulations Z and X published in the Federal Register in December 2013 and February 2015. Most of the changes to the procedures relate to the integrated mortgage disclosure requirements under TILA and RESPA, commonly referred to as the TRID requirements, which go into effect August 1 for all national banks and federal savings associations that offer consumer credit products covered by TILA and RESPA.

The Office of the Comptroller of the Currency is in the process of incorporating these revised interagency procedures into the “Truth in Lending Act” and “Real Estate Settlement Procedures Act” booklets of the Comptroller’s Handbook, which will supplant the interagency procedures once the updates are completed.

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