Regulatory Compliance
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Annual Thanksgiving and Annual Adjustments

In case you were distracted last week by family visiting, a plethora of football games and lots of food, the CFPB and Federal Reserve Board also announced the annual increase to the Regulation Z and Regulation M threshold for exempt consumer credit and lease transactions.

The Dodd-Frank Act, Truth in Lending Act (TILA), and Consumer Leasing Act require these thresholds to be adjusted annually based on the annual percentage increase in the Consumer Price Index for Urban Wage Earners and Clerical Workers. Transactions at or below the thresholds are subject to the protections of the regulations.

The adjustments to the thresholds will take effect on January 1, 2013. The protections of the Truth in Lending Act (TILA) and the Consumer Leasing Act will generally apply to consumer credit transactions and consumer leases of $53,000 or less in 2013. Keep in mind that private education loans and loans secured by real property are subject to TILA regardless of the amount of the loan.

The CFPB also announced an adjustment to the dollar amount that triggers additional protections for certain home mortgages under the Home Ownership and Equity Protection Act of 1994 (HOEPA). The HOEPA fee trigger will increase to $625 for 2013.

Click here for the CFPB’s press release and links to the notices published in the Federal Register.  

I hope everyone had a great Thanksgiving!

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