CFPB Issues TILA (Regulation Z) Annual Threshold Adjustments

The CFPB recently amended TILA’s implementing Regulation Z to update the dollar amounts of various thresholds for several provisions that are adjusted annually.  The threshold adjustments will be effective January 1, 2020.

For open-end consumer credit plans under TILA, the threshold triggering requirements to disclose minimum interest charges will remain unchanged at $1.00.

For open-end consumer credit plans under the CARD Act amendments to TILA, the adjusted dollar amount for the safe harbor for a first violation penalty fee will increase by $1 to $29, and the adjusted dollar amount for the safe harbor for a subsequent violation penalty fee will increase by $1 to $40.

For HOEPA loans, the adjusted total loan amount threshold for high-cost mortgages in 2020 will increase by $431to $21,980. The adjusted points and fees dollar trigger for high-cost mortgages will increase by $22 to $1,099.

For the general rule to determine consumers’ ability to repay mortgage loans, the maximum thresholds for total points and fees for qualified mortgages will increase to the following amounts:

• 3 percent of the total loan amount for a loan greater than or equal to $109,898;
• $3,297 for a loan amount greater than or equal to $65,939 but less than $109,898;
• 5 percent of the total loan amount for a loan greater than or equal to $21,980 but less than $65,939;
• $1,099 for a loan amount greater than or equal to $13,737 but less than $21,980; and
• 8 percent of the total loan amount for a loan amount less than $13,737.