Archive

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 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 […]

CFPB PUBLISHES ADDITIONAL THRESHOLDS FOR REGULATIONS M AND Z

On October 30, 2019 the CFPB published final rules in the Federal Register adjusting exemptions thresholds in Regulations Z and M for the year 2020. Comment 35(c)(2)(ii)-3.vii will be added to the Official Interpretations of § 1026.35 of Regulation Z to increase the threshold amount to $27,200 for the exemption from the special appraisal requirements for higher-priced mortgage loans. Comment 3(b)-3.xi will be added to the Official Interpretations of § 1026.3 of Regulation Z to increase the threshold amount […]

Regulations Z, M and HPML Appraisal Thresholds Adjusted for 2019

On November 23, 2018 federal banking agencies released two threshold adjustments for 2019, the Regulation Z and M exemption thresholds and the HPML appraisal threshold. Regulation Z and M Exemption Threshold: The Board of Governors of the Federal Reserve System (the Board) and the Bureau of Consumer Financial Protection (the Bureau) published final rules amending commentary and interpretations of their regulations which implement the Truth in Lending Act and Consumer Leasing Act, including the Bureau’s […]

2016 LENDING COMPLIANCE THRESHOLDS

Numerous regulatory requirements have thresholds that change annually. Following is a review of several of the lending thresholds that have changed recently. CRA – Small Bank and Intermediate Small Bank – Effective January 1, 2016 each federal financial institution regulatory agency defines the term “small bank” to mean a bank that, as of December 31 of either of the prior two calendar years, had assets of less than $1.216 billion. The term “intermediate small bank” means a small […]