The Office of the Comptroller of the Currency (OCC) recently issued a statement giving guidance on how it intends to interpret initial examinations for compliance with the TILA–RESPA Integrated Disclosure Rule (TRID). The guidance applies to national banks and federal savings associations with $10 billion or less in total assets.
The OCC intends to take an approach similar to the way it examined institution following implementation of the Dodd-Frank Act. The agency states it will be looking at an institution’s system for managing compliance and good faith efforts to carry out the new requirements. Among other things, the OCC will take into account a bank’s actions in updating policies and procedures, training staff, and responses to technical problems.
The OCC also stated it is in the process of updating the Comptroller’s Handbook to take into account the changes resulting from TRID. Until the Handbook is updated, supervised institutions can look to the OCC Bulleting 2015-27, “Consumer Compliance: Revised Interagency Examination Procedures for Consumer Compliance” for additional information regarding examination procedures.
The links featured below will direct you to the bulletins.
Initial Examinations for Compliance with TILA-RESPA Integrated Disclosure Rule
Revised Interagency Examination Procedures for Consumer Compliance