FDIC Issues Supervisory Expectations for Implementing TRID
By Anna DeSimone
October 2, 2015 the FDIC issued FIL-43-2015 to provide guidance on its initial supervisory expectations in connection with its examinations of financial institutions for compliance with the TILA – RESPA Integrated Disclosure Rule (TRID) effective October 3, 2015.
Statement of Applicability to Institutions Under $1 Billion in Total Assets:
This Financial Institution Letter applies to all FDIC-supervised institutions
Highlights:
- If mortgage loans are part of the scope of an FDIC consumer compliance examination, examiners will use interagency examination procedures to evaluate financial institutions for compliance with the TRID Rule. These procedures are available in the FDIC’s Compliance Examination Manual.
- During initial examinations for compliance with the TRID Rule, FDIC examiners will evaluate an institution’s compliance management system and overall efforts to come into compliance, recognizing the scope and scale of changes necessary for each supervised institution to achieve effective compliance.
- Examiners will expect supervised entities to make good faith efforts to comply with the TRID Rule’s requirements in a timely manner. Specifically, examiners will consider the institution’s implementation plan, including actions taken to update policies, procedures, and processes, its training of appropriate staff, and its handling of early technical problems or other implementation challenges.
- The FDIC’s supervisory approach regarding the TRID Rule will be similar to the approach the FDIC took in initial examinations for compliance with the Ability-to-Repay/Qualified Mortgage rules that became effective in January, 2014.
About the Author
Anna DeSimone is President and Founder of Bankers Advisory and Principal of CliftonLarsonAllen LLP. She can be reached at Anna@bankersadvisory.com
Anna DeSimone founded Bankers Advisory in 1986 and is a nationally recognized authority in residential mortgage lending. She has received numerous industry awards and has authored more than 40 best practices guides and hundreds of articles.
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