On November 6, 2015, the Office of the Comptroller of the Currency (OCC) issued Bulletin 2015-42 to provide guidance on initial examinations of OCC-supervised institutions with the new Truth-in-Lending and Real Estate Settlement Procedures Act Integrated Disclosures (TRID) rule. In the Bulletin, the OCC indicates that the initial examinations will review compliance management systems and overall efforts to come into compliance. Moreover, the Bulletin indicates that OCC examiners will expect supervised institutions to make good faith efforts to comply in a timely manner. In the initial reviews, examiners will be considering implementation plans, training of staff and handling of technical problems since the October 3, 2015 effective date of TRID.

OCC Bulletin 2015-42 can be found at: http://www.occ.treas.gov/news-issuances/bulletins/2015/bulletin-2015-42.html.