The FDIC has revised its interagency examination procedures to reflect the requirements of the TILA/RESPA integrated disclosures (TRID) rule. The CFPB has issued a proposal to postpone the TRID rule’s effective date from August 1 to October 3, 2015.
The revised procedures also reflect the following amendments to other provisions of TILA Regulation Z and RESPA Regulation X:
- the alternative definition of the term “small servicer” for certain nonprofit entities in the mortgage servicing rules
- the provisions in the ability-to-repay/qualified mortgage rule that give creditors or assignees meeting certain requirements a limited period of time in which to review a transaction and “cure” excess points and fees for purposes of maintaining QM status
- additional exempt transactions under the appraisal rule for higher-priced mortgage loans
In May 2015, the OCC released revisions to the TILA and RESPA chapters of its examination manual for consumer compliance exams to incorporate the requirements of the TRID rule.