CFPBFFIEC Rev 52011TILA 1 Truth in Lending ActBackground and Summary The Truth in Lending Act TILA 15 USC 1601 et seq was enactedon May 29 1968 as title I of the Consumer Credit Protection Ac ID: 849422
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1 CFPB Consumer Lawsand Regulations TILA C
CFPB Consumer Lawsand Regulations TILA CFPBFFIEC Rev. 5/2011TILA 1 Truth in Lending ActBackground and Summary The Truth in Lending Act (TILA), 15 USC 1601 et seq., was enactedon May 29, 1968, as title I of the Consumer Credit Protection Act (Pub. L. 90-3 CFPB Examination Procedures TILA Exam Date: Prepared By: Reviewed By: Docket #: CFPB Examination Procedures FFIEC Rev. 5/2011 TILA 1 Examination Objectives To appraise the quality of the financial institutions compliance management system for the Truth in Lending Act (TILA) and Regulation Z. To determine the reliance that can be placed on the financial institutions compliance management system, including internal controls and procedures performed by the person(s) responsible for monitoring the financial institutions compliance review function for the Truth in Lending Act and Regulation Z. To determine the financial institutions compliance with the Truth in Lending Act and R
2 egulation Z. To initiate corrective act
egulation Z. To initiate corrective action when policies or internal controls are deficient, or when violations of law or regulation are identified. To determine whether the institution will be required to make adjustments to consumer accounts under the restitution provisions of the Act. General Procedures Obtain information pertinent to the area of examination from the financial institutions compliance management system program (historical examination findings, complaint information, and significant findings from compliance review and audit). Through discussions with management and review of the following documents, determine whether the financial institutions internal controls are adequate to ensure compliance in the area under review. Identify procedures used daily to detect errors/violations promptly. Also, review the procedures used to ensure compliance when changes occur (e.g., changes in interest rates, service charges, s
3 oftware programs). Organizational chart
oftware programs). Organizational charts. Process flowcharts. Policies and procedures. Loan documentation and disclosures. Checklists/worksheets and review documents. Computer programs. CFPB Appendix A Consumer Laws and Regulations TILA Exam Date: Prepared By: Reviewed By: Docket #: CFPB FFIEC 5/2011 TILA Appendix A 1 Truth in Lending Act HIGH-COSTMORTGAGEWORKSHEET Borrowers NameLoan Number COVERAGE Is the loan secured by the consumers principal dwelling? [§226.2(a)(19), §226.32(a)(1)] If the answer is No, STOP HERE Is the loan for the following purpose? 1. Residential Mortgage Transaction [§226.2(a)(24)] 2. Reverse Mortgage Transaction [§226.33] 3. Open-End Credit Plan Subpart B [note prohibition against structuring loans as open-end plans to evade §226.32 [§226.34(b)] If the answer is Yes to Box 1, 2, or 3, STOP HERE. If No, continue to Test