On December 23, 2022, the Consumer Financial Protection Bureau (CFPB) will issue a final rule amending the regulation text and official interpretations for Regulation Z, which implements the Truth in Lending Act (TILA). The CFPB is adjusting these amounts, where appropriate, based on the annual percentage change reflected in the Consumer Price Index (CPI) in effect on June 1, 2022.
The revisions include:
- 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 2023.
- For HOEPA loans, the adjusted total loan amount threshold for high-cost mortgages in 2023 will be $24,866.
- The adjusted points-and-fees dollar trigger for high-cost mortgages in 2023 will be $1,243.
- For qualified mortgages (QMs) under the General QM loan definition in § 1026.43(e)(2), the thresholds for the spread between the annual percentage rate (APR) and the average prime offer rate (APOR) in 2023 will be:
- 2.25 or more percentage points for a first-lien covered transaction with a loan amount greater than or equal to $124,331;
- 3.5 or more percentage points for a first-lien covered transaction with a loan amount greater than or equal to $74,599 but less than $124,331;
- 6.5 or more percentage points for a first-lien covered transaction with a loan amount less than $74,599;
- 6.5 or more percentage points for a first-lien covered transaction secured by a manufactured home with a loan amount less than $124,331;
- 3.5 or more percentage points for a subordinate-lien covered transaction with a loan amount greater than or equal to $74,599; or
- 6.5 or more percentage points for a subordinate-lien covered transaction with a loan amount less than $74,599.
- For all categories of QMs, the thresholds for total points and fees in 2023 will be:
- 3 percent of the total loan amount for a loan greater than or equal to $124,331;
- $3,730 for a loan amount greater than or equal to $74,599 but less than $124,331;
- 5 percent of the total loan amount for a loan greater than or equal to $24,866 but less than $74,599;
- $1,243 for a loan amount greater than or equal to $15,541 but less than $24,866; and
- 8 percent of the total loan amount for a loan amount less than $15,541.
The final rule is effective January 1, 2023.
The annual thresholds for all lending compliance regulations are available on the Compliance Resource website. The site is being updated now and the full information will be available next week.