CFPB and Fed announce increases in Regs Z and M 2015 dollar thresholds

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The CFPB and Fed have announced increases in the dollar thresholds in Regulation Z (Truth in Lending Act) and Regulation M (Consumer Leasing Act) for exempt consumer credit and lease transactions. The adjustments reflect the annual percentage increase in the consumer price index as of June 1, 2014 and will take effect on January 1, 2015. The adjustments are issued jointly by the two agencies because, while Dodd-Frank generally transferred TILA and CLA rulemaking authority to the CFPB, the Fed retains authority to issues rules for certain motor vehicle dealers.

Both threshold are increased by $1,100 so that in 2015, Regs Z and M will apply to, respectively, credit transactions and consumer leases of $54,600 or less. (Private education loans and loans secured by real property or personal property used or expected to be used as a principal dwelling are subject to TILA regardless of the amount of the loan.)

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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