OCC Updates Truth in Lending Act Booklet

On 9/30/2020, the Office of the Comptroller of the Currency rescinded their “Truth in Lending Act” booklet from the Comptroller’s Handbook and instructed examiners to rely on revised interagency procedures. In their release, the OCC explains that the FFIEC has adopted revised interagency examination procedures for the Truth in Lending Act and the revised interagency procedures reflect amendments to Regulation Z published in the Federal Register through May 18, 2018.

Specifically, the OCC explains that the interagency procedures reflect

  • amendments to Regulation Z that relate to the TILA-RESPA Integrated Mortgage Disclosure Rule.3

  • amendments to TILA relating to the Economic Growth, Regulatory Relief, and Consumer Protection Act, including

    • provisions relating to high-cost loans, appraisals, and student lending.

    • an additional type of qualified mortgage for insured depository institutions with less than $10 billion in assets.

    • an additional type of escrow exemption for insured depository institutions with less than $10 billion in assets.

The full OCC release can be found here.

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