CFPB publishes annual threshold adjustments for TILA (Z regulation) | Weiner Brodsky Kider PC
The CFPB recently amended TILA implements Regulation Z by updating the dollar amounts of various thresholds for several provisions that are adjusted each year. The threshold adjustments will take effect on January 1, 2021.
For indefinite consumer credit plans under TILA, the threshold for minimum interest charge disclosure will remain unchanged at $ 1.00.
For indefinite consumer credit plans under the CARD changes made by TILA, the dollar amount adjusted for safe zones for first violation penalty fee and subsequent violation penalty fee remains unchanged at $ 29 and $ 40, respectively.
For HOEPA loans, the adjusted total loan amount threshold for high cost mortgages will increase by $ 72 to $ 22,052. The adjusted dollar point and fee trigger for high cost mortgages will increase from $ 4 to $ 1,103.
For qualifying mortgages and to determine a consumer’s ability to repay, the maximum thresholds for total points and fees will increase as follows:
- 3 percent of the total loan amount for a loan greater than or equal to $ 110,260;
- $ 3,308 for a loan amount greater than or equal to $ 66,156 but less than $ 110,260;
- 5 percent of the total loan amount for a loan greater than or equal to $ 22,052 but less than $ 66,156;
- $ 1,103 for a loan amount greater than or equal to $ 13,783 but less than $ 22,052; and
- 8 percent of the total amount for a loan amount less than $ 13,783.