OCC Bulletin 2020-84| September 30, 2020

Truth in Lending Act: Revised Interagency Examination Procedures


Chief Executive Officers of All National Banks, Federal Savings Associations, and Federal Branches and Agencies; Department and Division Heads; All Examining Personnel; and Other Interested Parties


The Task Force on Consumer Compliance of the Federal Financial Institutions Examination Council1 (FFIEC) has adopted revised interagency examination procedures for the Truth in Lending Act (TILA), implemented by Regulation Z. The revised interagency procedures reflect amendments to Regulation Z published in the Federal Register through May 18, 2018.


This bulletin rescinds the "Truth in Lending Act" booklet of the Comptroller's Handbook. Office of the Comptroller of the Currency (OCC) examiners should rely on the revised interagency procedures. Also rescinded is OCC Bulletin 2018-31, "Truth in Lending Act: Revised Comptroller's Handbook Booklet and Rescissions."

Note for Community Banks

These interagency procedures apply to the examinations of all OCC-supervised banks covered by TILA.2


The FFIEC members developed these procedures to promote consistency in the examination process and communication of supervisory expectations. These 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.

Further Information

Please contact Paul R. Reymann, Director for Consumer Compliance Policy, at (202) 649-5470.


Grovetta N. Gardineer
Senior Deputy Comptroller for Bank Supervision Policy

Related Links

1 The FFIEC consists of the following six voting members: a member of the Board of Governors of the Federal Reserve System; the Chair of the Federal Deposit Insurance Corporation; the Director of the Consumer Financial Protection Bureau; the Comptroller of the Currency; the Chair of the National Credit Union Administration; and the Chair of the State Liaison Committee.

2 "Banks" refers to national banks, federal savings associations, and federal branches and agencies of foreign banking organizations. The OCC has TILA/Regulation Z supervisory authority only for banks with $10 billion or less in assets. Refer to 12 CFR 1026.1(c), "Coverage," for details about banks covered by TILA.

3 RESPA stands for Real Estate Settlement Procedures Act. Refer to 82 Fed. Reg. 37656 and 83 Fed. Reg. 19159.