REGULATION Z THRESHOLD ADJUSTMENTS FOR 2020

On August 1, 2019, the Consumer Financial Protection Bureau (CFPB) released a final rule updating certain Regulation Z threshold amounts for 2020.  The adjusted thresholds affect amounts under the Credit Card Accountability Responsibility and Disclosure Act of 2009 (CARD Act), the Home Ownership and Equity Protection Act of 1994 (HOEPA), and the Dodd-Frank Wall Street Reform and Consumer Protection Act (Qualified Mortgages).

The adjusted amounts, effective January 1, 2020, include:

  • The open-end consumer credit minimum interest charge disclosure threshold which will remain unchanged at $1.00;
  • The open-end consumer credit plan safe harbor violation penalty fee will adjust up to $29 (first violation) and $40 (subsequent violation);
  • The total loan amount threshold for high-cost mortgages will increase to $21,980;
  • The points-and-fees dollar trigger for high-cost mortgages will increase to $1,099;
  • The qualified mortgages maximum thresholds for total points and fees will be:
    • 3 percent of the total loan amount for a loan greater than or equal to $109,898;
    • $3,297 for a loan amount greater than or equal to $65,939 but less than $109,898;
    • 5 percent of the total loan amount for a loan greater than or equal to $21,980 but less than $65,939;
    • $1,099 for a loan amount greater than or equal to $13,737 but less than $21,980; and
    • 8 percent of the total loan amount for a loan amount less than $13,737.

Compliance Resource compiles these and all pertinent lending thresholds for you in one easy to use chart. Each threshold is updated as it is released. The Lending Thresholds Chart is available on the “Resources” page of our website.

The final rule is available here.

 

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