FDIC ISSUES SUPERVISORY EXPECTATIONS FOR TRID

Friday, October 2, 2015 at 4:23pm, the FDIC issued Financial Institution Letter 43-2015 which provides insight into what financial institutions can anticipate when examined by the FDIC in upcoming months.
The FIL highlighted its initial supervisory expectations including:

  • The use of the interagency examination procedures to evaluate financial institutions for compliance with the TRID rules. A copy of these procedures, which are available in the FDIC’s Compliance Examination Manual, is available here.
  • Financial institutions may expect their compliance management system to be reviewed during initial examinations for TRID along with an evaluation of the effort put forth to achieve compliance. The expectation is that a financial institution made a “good faith” effort to timely comply with TRID requirements.  The FIL states that the examiners will specifically consider, “the institution’s implementation plan, including actions taken to update policies, procedures and processes, its training of appropriate staff, and its handling of early technical problems or other implementation challenges”.
  • Finally, the FIL stated that the approach to TRID examinations will be similar to the approach the FDIC took when initially examining compliance with the ATR/QM rules in 2014.

So, on this first full week of business after the October 3rd implementation date of TRID, this appears to be a bit of good news for those financial institutions regulated by the FDIC who worked diligently to prepare for the implementation date.  There is now at least some guidance as to what to expect in terms of examinations for TRID.  Hopefully, the other regulatory agencies will follow suit this week and create some consistency in the industry.

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