REVISED INTERAGENCY EXAMINATION PROCEDURES FOR REGULATION Z

Several sources recently reported that the Task Force on Consumer Compliance of the Federal Financial Institutions Examination Council approved revised interagency examination procedures for Regulation Z – Truth in Lending. So, is this a significant event? Does your bank need to do anything in response?

The primary revisions to the examination procedures result from the July 21, 2011 transfer of Regulation Z from the Federal Reserve Board to the Consumer Financial Protection Board.  To minimize any potential confusion, the CFPB preserved the numbering system of the Board’s Regulation Z in a new part of the Code of Federal Regulations (12 CFR part 1026). In others words the citations have changed.

I have always advocated the use of the examination procedures for internal audit. There are minimal changes to the actual procedures. So, you don’t really need to update the procedures.

Whether you use the examination procedures for internal audit or not, you should update policies, procedures, training materials and other related documents to reflect the citations that changed 17 months ago.

A copy of the revised audit procedures are available at https://www.federalreserve.gov/bankinforeg/caletters/CA_12-13-attachment.pdf

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