Consumer Affairs Letters

The Task Force on Consumer Compliance of the Federal Financial Institutions Examination Council recently approved the attached interagency examination procedures for Regulation Z – Truth in Lending.  These revised examination procedures supersede the Regulation Z interagency examination procedures transmitted with CA Letter 11-8. 

The attached examination procedures primarily reflect recent revisions to Regulation Z.  On July 21, 2011, the Board’s rulemaking authority under the Truth in Lending Act was transferred to the Consumer Financial Protection Bureau (CFPB).  On December 22, 2011, the CFPB published an interim final rule restating Regulation Z (76 Fed. Reg. 79768) to reflect the transfer of authority and certain other changes made by the Dodd-Frank Wall Street Reform and Consumer Protection Act.  The interim final rule did not impose any new substantive obligations on persons subject to the existing Regulation Z previously published by the Board.  Rather, it substantially duplicates the Board’s Regulation Z, making only certain non-substantive, technical, formatting, and stylistic changes.  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).[1]  Additional revisions were made to the examination procedures where supplementary information or other clarifications were deemed to be necessary, including to the section relating to open-end credit annual percentage rate calculations.

If you have any questions, please contact Lanette Meister, Senior Supervisory Consumer Financial Services Analyst, at (202) 452-2705, or Carol Evans, Assistant Director, at (202) 452-2051.