Truth-in-lending supervisory booklet updated by OCC

A supervisory booklet for bank examiners to use in reviewing Truth in Lending Act (TILA) compliance has been updated to reflect changes in mortgage servicing rules, the definition of small creditor and more.

The booklet, published by the Office of the Comptroller of the Currency (OCC) and announced Wednesday in Bulletin 2018-31, applies to examinations of OCC-supervised institutions that offer or extend consumer credit products covered by TILA.

The updated booklet replaces one from December 2014 and includes procedures implementing the Truth in Lending Act/Real Estate Settlement Procedures Act (TILA/RESPA) integrated mortgage disclosures rule issued by the Bureau of Consumer Financial Protection (BCFP, formerly known as CFPB).

The OCC also rescinded its Bulletin 2014-61, “Truth in Lending Act: Revised Comptroller’s Handbook Booklet and Rescissions” (December 16, 2014); and the TILA sections of Bulletin 2015-27, “Revised Interagency Examination Procedures for Consumer Compliance” (May 1, 2015), and Bulletin 2015-42, “Initial Examinations for Compliance With TILA-RESPA Integrated Disclosure Rule” (November 6, 2015).

OCC Bulletin 2018-31