Chief executives and compliance officers of small- to mid-sized banks have been advised about what to expect in integrated disclosure rule compliance examinations.
The
Truth in Lending Act and Real Estate Settlement Procedures Act Integrated Disclosure Rule went into effect for loans with an application taken on or after Oct. 3.
The rule from the Consumer Financial Protection Bureau includes a new Loan Estimate and a new Closing Disclosure. Both forms replace previously used disclosures.
In
Bulletin 2015-42, the Office of the Comptroller of the Currency provided guidance about initial examinations it will conduct on compliance with TRID.
The notice was directed at chief executive officers and compliance officers of national banks and federal savings associations with no more than $10 billion in total assets.
According to the OCC,
examiners will evaluate a bank’s compliance management system and overall efforts to come into compliance.
OCC said its examiners will remain conscious of the scope and scale of changes necessary for each bank to achieve effective compliance.
But examiners expect banks to
make good-faith efforts to be in compliance with the rule’s requirements in a timely manner.
“Specifically, examiners are considering the bank’s implementation plan, including actions taken to update policies, procedures, and processes, as well as training of appropriate staff and handling of early technical problems or other implementation challenges,” the bulletin said.
The regulator noted that it intends to take the same approach as it did with the CFPB’s rules that implemented provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act which became effective in January 2014.
Revised OCC procedures for TRID are being incorporated into the TILA and RESPA
booklets of the Comptroller’s Handbook.
