The Office of the Comptroller of the Currency has released revised TILA and RESPA chapters of its examination manual for consumer compliance exams. The revised chapters incorporate the detailed procedural and substantive requirements of the CFPB’s TILA/RESPA integrated disclosures (TRID) rule, which is set to go into effect on August 1, 2015. The OCC’s publication of the chapters follows a similar release from the CFPB in April 2015.
The OCC’s versions of the TILA and RESPA chapters appear nearly the same as the CFPB’s, except for minor formatting adjustments and technical changes. While this likely reflects the agencies’ coordination of examination procedures through the Federal Financial Institutions Examination Council, it offers little insight into how, and to what extent, exam priorities may differ for depository institutions, as compared to their non-bank counterparts in the mortgage space.
The other three federal banking agencies—the Federal Reserve, the FDIC, and the NCUA—have yet to update their examination manuals to include the TRID requirements. For the time being, creditors under their supervisory jurisdiction should be able to rely on the versions published to date by the CFPB and the OCC.