ANNUAL UPDATE TO TILA DOLLAR AMOUNTS

On July 25, 2017 the Consumer Financial Protection Bureau (CFPB) approved a final rule that amends various dollar amounts that impact requirements of the Truth in Lending and Act and Regulation Z. The rule was published on August 30, 2017. This is an annual event.

The revised amounts are effective on January 1, 2018. Be sure to update your procedures and systems to reflect the revised amounts as of the effective date.

The revised amounts:

  • For open-end consumer credit plans under TILA, the threshold that triggers requirements to disclose minimum interest charges will remain unchanged at $1.00 in 2018.
  • For open-end consumer credit plans under the CARD Act amendments to TILA, the adjusted dollar amount for the safe harbor for a first violation penalty fee will remain unchanged at $27 in 2018 and the adjusted dollar amount for the safe harbor for a subsequent violation penalty fee will remain unchanged at $38 in 2018.
  • For HOEPA loans, the adjusted total loan amount threshold for high-cost mortgages in 2018 will be $21,032. The adjusted points and fees dollar trigger for high-cost mortgages in 2018 will be $1,052.
  • For the general rule to determine consumers’ ability to repay mortgage loans, the maximum thresholds for total points and fees for qualified mortgages in 2018 will be:
    • 3 percent of the total loan amount for a loan greater than or equal to $105,158;
    • $3,155 for a loan amount greater than or equal to $63,095 but less than $105,158;
    • 5 percent of the total loan amount for a loan greater than or equal to $21,032 but less than $63,095;
    • $1,052 for a loan amount greater than or equal to $13,145 but less than $21,032; and
    • 8 percent of the total loan amount for a loan amount less than $13,145.

More information about the final rule is available at: https://www.federalregister.gov/documents/2017/08/30/2017-18003/truth-in-lending-regulation-z-annual-threshold-adjustments-credit-cards-hoepa-and-atrqm

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