Compliance Blog

Apr 13, 2010
Categories: Consumer Lending

OTS Updates its Exam Procedures for Reg Z, Private Student Loans and Mortgage Transfers

Posted by Anthony Demangone

The Office of Thrift Supervision (OTS) has updated its Truth in Lending Act and Regulation Z examination procedures.  OTS issued a CEO Letter to announce the change, which provides a nice overview of the changes.  The CEO Letter also links to the updated procedures, which are a fantastic overview of Regulation Z's requirements.  The letter notes that the exam procedures are being updated in three areas:
  1. Open end provisions of Regulation Z.
  2. Private student loans. 
  3. Notice of mortgage transfers.  
I understand that OTS does not regulate credit unions.  But the OTS is part of the Federal Financial Institution Examination Council, as is NCUA.  The rules for thrifts and credit unions, when it comes to TILA and Regulation Z, are virtually identical.  So I think this would be a very useful tool for you and your compliance shop.