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 of Regulation Z will continue to apply to consumer credit transactions of $58,300 or less in 2021 (ยง 1026.3(b)(1)). The same threshold is applicable to Regulation M. Loans secured by real property (i.e. mortgages) and private education loans are subject to the Truth in Lending Act regardless of the amount of the loan; and
  • The HPML Appraisal Exemption Threshold contained in 1026.35(c)(2)(ii) remains $27,200. Loans at or below this amount will be exempt from the HPML appraisal rules.

These thresholds will be applicable from January 1, 2021 through December 31, 2021.

The Compliance Resource Lending Thresholds Chart provides the most recent information on all lending thresholds. It is available at: https://www.jackscomplianceresource.com/ultimate-compliance-resource/.

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