A 2020 bulletin on revised Truth-in-Lending Act (TILA) exam procedures was rescinded by the national regulator of banks Thursday in light of more recent revisions brought about by changes regarding the definitions of qualified mortgages.
The Office of the Comptroller of the Currency (OCC), in Thursday’s Bulletin 2021-51, noted that the Task Force on Consumer Compliance of the Federal Financial Institutions Examination Council (FFIEC) has adopted revised interagency examination procedures that reflect amendments to Regulation Z (which implements TILA) published in the Federal Register through May 30, 2021; this includes the changes made by the Consumer Financial Protection Bureau (CFPB) to its QM rules and the tweaks that followed.
In light of the changes in the QM rules and the FFIEC exam procedures, the OCC said it has has rescinded Bulletin 2020-84, “Truth in Lending Act: Revised Interagency Examination Procedures,” along with the procedures conveyed by that document.
The OCC noted that the FFIEC’s exam procedure revisions address the new general QM definition, the new category of QMs called “seasoned” QMs; the delay until Oct. 1, 2022, in the mandatory compliance date for the new general QM definition; and the extended sunset date for the temporary GSE QM (or “GSE patch”), which is the earlier of the GSEs’ (Fannie Mae and Freddie Mac) exit from conservatorship or the implementation of the new general QM definition.