CFPB and FRB Announce Annual Threshold Adjustments for TILA and CLA

The CFPB and Federal Reserve Board (FRB) (collectively, the Agencies) recently amended TILA’s implementing Regulation Z and the Consumer Leasing Act’s (CLA) implementing Regulation M by updating dollar thresholds that are adjusted annually.  The threshold adjustments will be effective January 1, 2023.

The Agencies use the dollar threshold adjustments to determine whether certain consumer credit transactions and consumer leases are exempt from Regulation Z and Regulation M, respectively.  These dollar thresholds are adjusted based on the annual percentage increase in the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI–W).  Because the CPI–W increased 8.9 percent as of June 1, 2022, consumer credit transactions and consumer leases greater than $66,400 in 2023, up from $61,000 in 2022, are exempt from Regulation Z and Regulation M.