2013 THRESHOLDS

On November 20, 2013 the Consumer Financial Protection Bureau published notices increasing several thresholds for 2013.  Two notices increased the dollar thresholds in Regulation Z (Truth in Lending) and Regulation M (Consumer Leasing) for exempt consumer credit and lease transactions. The Dodd-Frank Act amendment the Truth in Lending Act and the Consumer Leasing Act to adjust these thresholds annually by the annual percentage increase in the Consumer Price Index for Urban Wage Earners and Clerical Workers.

As of January 1, 2013 the Truth in Lending Act and the Consumer Leasing Act generally will apply to consumer credit transactions and consumer leases of $53,000 or less. 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 second notice adjusts the dollar amount that triggers additional protections for certain home mortgages under the Home Ownership and Equity Protection Act of 1994 (HOEPA), as required by statute. Consistent with the increase in the consumer price index, the dollar amount of the HOEPA fee trigger will increase to $625 for 2013 from the $611 that was in effect during 2012.

Neither the 2013 Home Mortgage Disclosure Act threshold nor the 2013 definitions of small bank and intermediate small bank under the Community Reinvestment Act have been announced.

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