CFPB and Fed Increase Reg Z Dollar Threshold
by: Marissa Aquila Blundell, Esq.
On November 20, 2012, the Consumer Financial Protection Bureau (CFPB), jointly with the Federal Reserve Board (FRB) where applicable, issued three final rules which adjust certain monetary thresholds in the Truth-in-Lending Act’s (TILA) Regulation Z and Consumer Leasing Act’s (CLA) Regulation M. The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank) requires the CFPB and FRB to adjust certain monetary thresholds annually based on any increase in the Consumer Price Index for Urban Wage Earners and Clerical Workers.
Each of the adjustments below is effective January 1, 2013.
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Reg. Z’s transaction “points and fees” threshold, the dollar amount triggering HOEPA’s additional consumer protections is raised to the greater of $625.00 or 8 percent of the loan amount, whichever is less.
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Reg. Z’s exemption threshold, the dollar amount above which a consumer credit transaction is exempt from TILA coverage is raised from $51,800.00 to $53,000.00. This exemption does not apply to loans secured by real or personal property used or expected to be used as the principal dwelling of a consumer and private education loans, which are subject to TILA regardless of amount.
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Regulation M’s exemption threshold, applicable to certain consumer leases, is likewise raised to $53,000.00.
About the Author:
Marissa is Senior Vice President & General Counsel at Bankers Advisory, Inc. She oversees the firms audit operations and state compliance rules published by AllRegs. She is a graduate of Skidmore College, earned her Juris Doctor at the New England School of Law and is admitted to the Massachusetts Bar. She is Co-chair of the Legislative Committee of the Massachusetts Mortgage Bankers Association. She can be reached at marissa@bankersadvisory.com
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