Archive

REGULATION Z CONSUMER CREDIT EXEMPTION AND HPML APPRAISAL THRESHOLDS UNCHANGED FOR 2021

On November 18 the Consumer Financial Protection Bureau (CFPB) and Federal Reserve Board (FRB) published the 2021 threshold for the consumer credit exemption in Regulations Z and M. Additionally, the CFPB, FRB, and Office of the Comptroller of the Currency (OCC) published the 2021 threshold for Higher Priced Mortgage Loan (HPML) appraisal exemption in Regulation Z. There will be no changes from the 2020 threshold amounts. The thresholds for 2021 are as follows: The protections […]

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CFPB PUBLISHES ADDITIONAL THRESHOLDS FOR REGULATIONS M AND Z

On October 30, 2019 the CFPB published final rules in the Federal Register adjusting exemptions thresholds in Regulations Z and M for the year 2020. Comment 35(c)(2)(ii)-3.vii will be added to the Official Interpretations of § 1026.35 of Regulation Z to increase the threshold amount to $27,200 for the exemption from the special appraisal requirements for higher-priced mortgage loans. Comment 3(b)-3.xi will be added to the Official Interpretations of § 1026.3 of Regulation Z to increase the threshold amount […]

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Regulations Z, M and HPML Appraisal Thresholds Adjusted for 2019

On November 23, 2018 federal banking agencies released two threshold adjustments for 2019, the Regulation Z and M exemption thresholds and the HPML appraisal threshold. Regulation Z and M Exemption Threshold: The Board of Governors of the Federal Reserve System (the Board) and the Bureau of Consumer Financial Protection (the Bureau) published final rules amending commentary and interpretations of their regulations which implement the Truth in Lending Act and Consumer Leasing Act, including the Bureau’s […]

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2016 LENDING COMPLIANCE THRESHOLDS

Numerous regulatory requirements have thresholds that change annually. Following is a review of several of the lending thresholds that have changed recently. CRA – Small Bank and Intermediate Small Bank – Effective January 1, 2016 each federal financial institution regulatory agency defines the term “small bank” to mean a bank that, as of December 31 of either of the prior two calendar years, had assets of less than $1.216 billion. The term “intermediate small bank” means a small […]

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THE CFPB INHERITS REGULATION M

The Consumer Leasing Act (CLA) was enacted in 1976 as an amendment to the Truth in Lending Act (TILA). The purpose of the CLA is to ensure meaningful and accurate disclosure of the terms of personal property leases for personal, family, or household use. The CLA and Regulation M require lessors to provide consumers with uniform cost and other disclosures about consumer lease transactions. The CLA has been implemented in Regulation M of the Board of […]

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