On May 4, the Consumer Financial Protection Bureau revised its mortgage origination examination procedures to provide guidance on how it will conduct compliance exams for the TILA-RESPA integrated disclosures that become effective on August 1, 2015.

The CFPB has revised version 2.0 of its Supervision and Examination Manual numerous times since it was released on October 1, 2012, including revisions on April 1, 2015 that incorporated the TILA/RESPA integrated disclosures requirements.

The CFPB’s release of these three revised chapters over the last six weeks may indicate that it has started training its examiners on the TILA-RESPA Integrated Disclosure Rule.  Coupled with the CFPB’s recent letter indicating it will not provide a grace period for enforcement of the TILA-RESPA Integrated Disclosure Rule, there appears little hope that the CFPB will voluntarily agree to delay the effective date beyond August 1, 2015.