Agencies Announce Thresholds For TILA, Consumer Leasing, and Higher-Priced Mortgage Loans

Last Friday, October 4th 2024, The CFPB (Consumer Financial Protection Bureau) and the  Federal Reserve Board (FRB) announced the dollar thresholds used to determine which consumer credit and lease transactions in 2025 are subject to specific protections under Regulation Z (Truth in Lending) and Regulation M (Consumer Leasing).

The thresholds are adjusted annually based on the percentage increase in the CPI-W (Consumer Price Index for Urban Wage Earners and Clerical Workers). So, based on the 3.4 percent annual percentage increase in the CPI-W as of June 1, 2024, Regulation Z and Regulation M generally will apply to consumer credit transactions and consumer leases of $71,900 or less in 2025.

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The CFPB, FRB and the OCC (Office of the Comptroller of the Currency) also announced on Friday announced that the 2025 threshold for higher-priced mortgage loans that are subject to special appraisal requirements will increase from $32,400 to $33,500.

The threshold is effective January 1, 2025 and is also based on the annual percentage increase in the CPI-W, as of June 1, 2024.

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