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WBK Industry News - Federal Regulatory Developments

CFPB Issues Truth in Lending (Regulation Z) Annual Threshold Adjustments

The CFPB has amended the official interpretations for Regulation Z to update the dollar amounts of various thresholds that are adjusted annually.  Effective January 1, 2018 the following threshold adjustments will be in effect.

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

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 remain unchanged at $27.00 and the adjusted dollar amount for the safe harbor for a subsequent violation penalty fee will remain unchanged at $38.00.

The HOEPA loan adjusted total loan amount threshold for high-cost mortgages will be $21,032.

For HOEPA loans, the adjusted total loan amount threshold for high-cost mortgages in 2018 will be $21,032. The adjusted points and fees dollar trigger for high-cost mortgages will be $1,052.

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

  • 3 percent of the total loan amount for a loan greater than or equal to $105,158;
  • $3,155 for a loan amount greater than or equal to $63,095 but less than $105,158;
  • 5 percent of the total loan amount for a loan greater than or equal to $21,032 but less than $63,095;
  • $1,052 for a loan amount greater than or equal to $13,145 but less than $21,032; and
  • 8 percent of the total loan amount for a loan amount less than $13,145.