2015-10-21
The Federal Reserve Board issued this guidance to outline supervisory expectations for institutions with total consolidated assets of $10 billion or less regarding compliance with the TILA-RESPA Integrated Disclosure Rule. Examiners will evaluate an institution's good faith efforts and compliance management systems during early examinations, considering implementation plans, staff training, and the handling of technical challenges. This approach aligns with previous supervisory practices for initial examinations of mortgage rules effective in January 2014 and utilizes interagency examination procedures for Regulation Z and Regulation X.