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FINAL 2022 LENDING THRESHOLDS PUBLISHED

On December 23, 2022, the Consumer Financial Protection Bureau (CFPB) published the final 2022 lending thresholds. The CFPB published a final rule amending Regulation C to reflect the asset-size exemption threshold for banks, savings associations, and credit unions based on the annual percentage change in the average of the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W). Based on the 4.7 percent increase in the average of the CPI-W for the 12-month […]

FINAL REGULATION Z RULES FOR LIBOR

On December 8, 2021 the Consumer Financial Protection Bureau (CFPB) amended Regulation Z, which implements the Truth in Lending Act (TILA), generally to address the anticipated sunset of LIBOR, which is expected to be discontinued for most U.S. Dollar (USD) tenors in June 2023. Some creditors currently use USD LIBOR as an index for calculating rates for open-end and closed-end products. The CFPB is amending: The open-end and closed-end provisions to provide examples of replacement […]

AGENCIES INCREASE REGULATION M AND Z THRESHOLDS

On November 29, 2021 the Office of the Comptroller of the Currency, Treasury (OCC); Board of Governors of the Federal Reserve System (Board); and Bureau of Consumer Financial Protection (Bureau) announced new coverage thresholds for: Consumer Leasing (Regulation M) – Based on the annual percentage increase in the CPI-W as of June 1, 2021, the exemption threshold will increase from $58,300 to $61,000 effective January 1, 2022. Appraisal for Higher-Priced Mortgage Loans Exemption Threshold – […]

REGULATION Z THRESHOLDS PUBLISHED

On October 25, 2021, the Consumer Financial Protection Bureau (CFPB) published a final rule amending Regulation Z and its Official Interpretations. The final rule revises the dollar amounts for provisions implementing TILA and amendments to TILA, including 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 (Dodd-Frank Act). The CFPB is […]

REVISED REGULATION Z EXAMINATION PROCEDURES

On October 25, 2021, the Board of Governors of the Federal Reserve System issued Consumer Affairs Letter (CA 21-14) announcing revised Interagency Examination Procedures for Regulation Z. The comprehensive procedures are 384 pages in length. The revised procedures reflect amendments to Regulation Z published by the Consumer Financial Protection Bureau in 2020 and 2021: Implementing permanent changes to Regulation Z’s qualified mortgage provisions, and Implementing an extension and phase-out for the GSE Patch, which had […]