UPDATED RESPA AND TILA EXAMINATION PROCEDURES

On April 19, 2018 the Federal Reserve Board published a Consumer Affairs Letter (CA 18-3) regarding Revised Interagency Examination Procedures for Regulation X and Regulation Z.

The Task Force on Consumer Compliance of the Federal Financial Institutions Examination Council recently developed the interagency examination procedures for the Real Estate Settlement Procedures Act (RESPA) and the Truth in Lending Act (TILA). The revised examination procedures supersede the examination procedures transmitted with CA Letter 15-6.

The procedures reflect the following amendments to Regulation Z and Regulation X published by the Consumer Financial Protection Bureau (CFPB):

  • Amendments to Regulation Z and Regulation X related to mortgage servicing that were effective in October 2017, unless otherwise specified; and
  • Other amendments to Regulation Z published through April 2016, including rules related to mortgage lending by small creditors serving rural and underserved areas.

The procedures do not incorporate the 2017 amendments to Regulation Z regarding the CFPB’s TILA-RESPA integrated disclosure rule or regarding prepaid accounts. Those amendments will be addressed in a future update.

The revised procedures are available at

Leave a Reply

Your email address will not be published. Required fields are marked *