Consumer Affairs Letters

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CA 18-3:

Revised Interagency Examination Procedures for Regulation X and Regulation Z

BOARD OF GOVERNORS
OF THE FEDERAL RESERVE SYSTEM
WASHINGTON, D.C. 20551

DIVISION OF CONSUMER
AND COMMUNITY AFFAIRS

CA 18-3
April 19, 2018

TO THE OFFICERS AND MANAGERS IN CHARGE OF CONSUMER AFFAIRS SECTIONS:

SUBJECT:

Revised Interagency Examination Procedures for Regulation X and Regulation Z

Applicability to Community Banking Organizations: This guidance applies to institutions supervised by the Federal Reserve with total consolidated assets of $10 billion or less.

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

The attached 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 X1 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.2

These procedures do not incorporate 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.

If you have any questions concerning this guidance, please contact Dana Miller, Counsel, at (202) 452-2751, or Amy Henderson, Managing Counsel, at (202) 452-3140. In addition, questions may be sent via the Board's public website.3

signed by
Carol Evans
Associate Director
Division of Consumer
and Community Affairs

Supersedes:

CA 15-6, “Revised Interagency Examination Procedures for Regulation Z and Regulation X” (Sept. 22, 2015)

Attachments:
Notes:
  1. Published by the CFPB in October 2016, July 2017, and October 2017 Return to text
  2. Published by the CFPB in October 2015 and March 2016. Return to text
  3. See http://www.federalreserve.gov/apps/contactus/feedback.aspx. Return to text
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Last Update: April 19, 2018