The CFPB has revised the chapters of its Supervision and Examination Manual specific to TILA and RESPA, incorporating the TILA/RESPA integrated disclosures (TRID) requirements that are set to take effect on August 1, 2015. These chapters replace versions of the TILA and RESPA procedures released on November 27, 2013.

As is the case for most statute-specific portions of the Manual, the TILA and RESPA chapters each contain two parts:  a narrative portion outlining the substantive requirements and restrictions of the law and its implementing regulation, and a detailed examination checklist. While neither portion of the new TILA and RESPA chapters sheds much light on the Bureau’s supervisory priorities with respect to early TRID rule exams, the narrative portion of the new TILA chapter does provide a good high-level summary of the rule, which aggregates the primary text with the relevant commentary. (Because the TRID rule installed its disclosure, timing, and other requirements in TILA’s Regulation Z, the new REPSA chapter merely cross-references the narrative portion of the new TILA chapter.)

More importantly, the CFPB’s release of these chapters signals that it has begun, or will shortly begin, intensive examiner training on the rule. The release also may indicate that the CFPB does not intend to delay the effective date of the rule beyond August 1. The industry will likely pursue a statement from the CFPB providing for some type of leniency in enforcement through 2015, and the CFPB’s decision to revise the examination guidance does not preclude it from issuing such a statement.

The narrative portion of the new TILA chapter specific to the TRID rule runs from page 35 through page 50, and the TILA examination procedures specific to the TRID rule run from page 4 through page 42. The narrative portion of the new RESPA chapter specific to the TRID rule is on page 5, and, as discussed above, the RESPA examination procedures include no instructions specific to the TRID rule.