OCC Provides Guidance for Initial TRID Examinations

November 10, 2015

The Office of the Comptroller of the Currency (OCC) provided guidance regarding initial examinations of OCC-supervised institutions for compliance with the TILA-RESPA Integrated Disclosure (TRID) rule.

The guidance applies to national banks and federal savings associations (collectively, banks) with $10 billion or less in total assets.

Highlights:

  • During initial examinations for compliance with the rule, OCC examiners are evaluating a bank’s compliance management system and overall efforts to come into compliance, recognizing the scope and scale of changes necessary for each bank to achieve effective compliance.
  • Examiners expect banks to make good-faith efforts to comply 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 OCC’s supervisory approach regarding the rule is similar to the approach the OCC took in initial examinations for compliance with the mortgage rules implementing provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act that went into effect in January 2014.

The OCC 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.


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