CFPB Issues Annual Threshold Adjustments for TILA (Regulation Z)

The CFPB recently amended TILA’s implementing Regulation Z by updating the dollar amounts of various thresholds for several provisions that are adjusted annually.  The threshold adjustments will be effective January 1, 2021.

For open-end consumer credit plans under TILA the threshold triggering disclosure of minimum interest charges will remain unchanged at $1.00.

For open-end consumer credit plans under the CARD Act amendments to TILA, the adjusted dollar amount for the safe harbors for both a first violation penalty fee and a subsequent violation penalty fee remain unchanged at $29 and $40, respectively.

For HOEPA loans, the adjusted total loan amount threshold for high-cost mortgages will increase by $72 to $22,052. The adjusted points-and-fees dollar trigger for high-cost mortgages will increase by $4 to $1,103.

For qualified mortgages and determining a consumer’s ability to repay, the maximum thresholds for total points and fees will increase as follows:

• 3 percent of the total loan amount for a loan greater than or equal to $110,260;
• $3,308 for a loan amount greater than or equal to $66,156 but less than $110,260;
• 5 percent of the total loan amount for a loan greater than or equal to $22,052 but less than $66,156;
• $1,103 for a loan amount greater than or equal to $13,783 but less than $22,052; and
• 8 percent of the total amount for a loan amount less than $13,783.