Increased Thresholds in Regulations Z and M for Exempt Consumer Credit and Lease Transactions and in TILA HPML Appraisal Exemption

The CFPB and the Federal Reserve Board (Board) announced increases in the dollar thresholds in Regulation Z (Truth in Lending) and Regulation M (Consumer Leasing) for exempt consumer credit and lease transactions.  Additionally, the exemption threshold for higher-priced mortgage loans (HPMLs) subject to the special appraisal requirements has been increased.

Based on the annual percentage increase in the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W) as of June 1, 2017, the protections of the Truth in Lending Act and the Consumer Leasing Act exemption threshold will increase from $54,600 to $55,800 effective January 1, 2018. However, private education loans and loans secured by real property (such as mortgages) are subject to the Truth in Lending Act regardless of the amount of the loan.

The notices may be found here:

Regulation M here: https://www.federalregister.gov/documents/2017/11/09/2017-24411/consumer-leasing-regulation-m.

Regulation Z here: https://www.federalregister.gov/documents/2017/11/09/2017-24445/truth-in-lending-regulation-z.

In another notice, the OCC, the Board, and the CFPB finalized amendments to the official interpretations for their regulations that implement section 129H of the Truth in Lending Act (TILA). More specifically, the amendments increase the exemption threshold for HPMLs subject to the special appraisal requirements.

Based on the CPI-W in effect as of June 1, 2017, the exemption threshold will increase from $25,500 to $26,000 effective Jan. 1, 2018.

The notice may be found here: https://www.federalregister.gov/documents/2017/11/09/2017-24443/appraisals-for-higher-priced-mortgage-loans-exemption-threshold.