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Board of Governors of the Federal Reserve System

Consumer Affairs Letters

CA 12-13

Revised Interagency Examination Procedures for Regulation Z

November 27, 2012

Seal of the Board of Governors of the Federal Reserve System
BOARD OF GOVERNORS
OF THE
FEDERAL RESERVE SYSTEM
WASHINGTON, D. C.  20551
DIVISION OF CONSUMER
AND COMMUNITY AFFAIRS
CA 12-13
November 27, 2012
TO THE OFFICERS AND MANAGERS IN CHARGE OF CONSUMER AFFAIRS SECTIONS
SUBJECT:   Revised Interagency Examination Procedures for Regulation Z
The Task Force on Consumer Compliance of the Federal Financial Institutions Examination Council recently approved the attached interagency examination procedures for Regulation Z – Truth in Lending.  These revised examination procedures supersede the Regulation Z interagency examination procedures transmitted with CA Letter 11-8. 

The attached examination procedures primarily reflect recent revisions to Regulation Z.  On July 21, 2011, the Board’s rulemaking authority under the Truth in Lending Act was transferred to the Consumer Financial Protection Bureau (CFPB).  On December 22, 2011, the CFPB published an interim final rule restating Regulation Z (76 Fed. Reg. 79768) to reflect the transfer of authority and certain other changes made by the Dodd-Frank Wall Street Reform and Consumer Protection Act.  The interim final rule did not impose any new substantive obligations on persons subject to the existing Regulation Z previously published by the Board.  Rather, it substantially duplicates the Board’s Regulation Z, making only certain non-substantive, technical, formatting, and stylistic changes.  To minimize any potential confusion, the CFPB preserved the numbering system of the Board’s Regulation Z in a new part of the Code of Federal Regulations (12 CFR part 1026).[1]  Additional revisions were made to the examination procedures where supplementary information or other clarifications were deemed to be necessary, including to the section relating to open-end credit annual percentage rate calculations.

If you have any questions, please contact Lanette Meister, Senior Supervisory Consumer Financial Services Analyst, at (202) 452-2705, or Carol Evans, Assistant Director, at (202) 452-2051.

[1] Certain changes were made to the text of the Board’s Regulation Z to conform to current codification standards of the Code of Federal Regulations.  Most significantly, the Board’s §§ 226.5a and 226.5b have been renumbered as §§ 1026.60 and 1026.40, respectively.  As § 226.5a related to credit card disclosures, the CFPB codified it as § 1026.60 so that it would appear in subpart G, Special Rules Applicable to Credit Card Accounts and Open-End Credit Offered to College Students.  As § 226.5b related to home-equity plans, the CFPB codified it as § 1026.40 so that it would appear in subpart E, Special Rules for Certain Home Mortgage Transactions. 

 

signed by
Sandra Braunstein
Director
Division of Consumer and Community Affairs


Supersedes:
CA Letter 11-8 “Revised Interagency Examination Procedures for Regulation Z” (December 23, 2011)
Last update: November 28, 2012