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Today is: November 21, 2018  

Compliance Companion®
Standard Procedures Manuals (SPM)

Truth in Lending Act & Regulation Z October 2018

This Manual serves as a comprehensive resource for compliance professionals, credit administrators, loan officers and loan documentation specialists regarding all aspects of the Truth in Lending Act and Regulation Z. The text of this Manual is 1,055 pages, plus 106 pages of appendices.

Part One of the Manual includes a summary of recent developments (as of September 2018) and a glossary of defined terms under Regulation Z.

Part Two discusses general compliance requirements that affect both closed-end and open-end credit, including:

  • Reg Z coverage and exemption rules
  • Determining what is and is not a finance charge
  • Record retention
  • APR and finance charge tolerances
  • Liability provisions under TILA (including a creditor’s liability for actual and statutory damages, assignee liability and the various statutes of limitations)
  • How to take corrective action (to cure a Regulation Z violation)
Part Three provides detailed discussions of Regulation Z’s closed-end credit requirements, including the form, timing and contents of the TIL disclosure statement at consummation, early disclosure rules for reverse mortgages subject to RESPA and the applicable waiting periods, construction loan disclosures under Appendix D, right of rescission, advertising requirements, and reverse mortgage transactions. Part Three also provides:
  • In-depth discussions of the TRID Loan Estimate and Closing Disclosure, including a discussion of TRID 2.0, especially as it relates to construction loans
  • Requirements regarding the ability-to-repay rule, higher-priced mortgages under Section 1026.35, high-cost mortgages under Section 1026.32, mortgage servicing rules (including periodic statements for mortgage loans), ARM transactions, and loan originator compensation and qualification requirements
Part Four covers the open-end credit requirements under Regulation Z, explaining the requirements governing:
  • Account-opening disclosures
  • Periodic statements
  • Right of rescission
  • Home equity lines of credit
  • Special credit card rules
  • Advertising requirements
  • Billing error resolution procedures
  • Complicated requirements regarding change-in-terms notices
  • Special rules that apply to credit card accounts and open-end credit offered to college students


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SPM 18

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