News & Analysis as of

Threshold Requirements Consumer Financial Protection Bureau (CFPB) Regulation Z

Orrick, Herrington & Sutcliffe LLP

CFPB adjusts asset-size exemption thresholds for Regulations C and Z

On December 18, the CFPB adjusted the asset-size exemption thresholds for Regulation C (as part of the Home Mortgage Disclosure Act) and Regulation Z (as part of TILA), based on a 4.1 percent increase in the average...more

Ballard Spahr LLP

CFPB/Fed/OCC increase exemption thresholds for appraisal requirement, Regs Z and M (UPDATED)

Ballard Spahr LLP on

The CFPB, Fed, and OCC have announced that they are increasing three exemption thresholds that are subject to annual inflation adjustments.  Effective January 1, 2024 through December 31, 2024, these exemption thresholds are...more

Troutman Pepper

Federal Agencies Announce Increased Regulations Z and M Dollar Thresholds for Exempt Consumer Credit and Lease Transactions, and...

Troutman Pepper on

On November 13, the Consumer Financial Protection Bureau (CFPB) and the Federal Reserve Board (Fed) announced increased dollar thresholds used to determine whether certain consumer credit and lease transactions in 2024 are...more

Goodwin

FinCEN Issues NPRM Regarding Access to Beneficial Ownership Information and Related Safeguards

Goodwin on

Regulatory Developments - FinCEN Issues NPRM Regarding Access to Beneficial Ownership Information and Related Safeguards - On December 15, FinCEN issued a Notice of Proposed Rulemaking (NPRM) that would implement...more

Ballard Spahr LLP

CFPB Adjusts HMDA and HPML Asset Exemption Thresholds

Ballard Spahr LLP on

The CFPB recently issued a final rule increasing the asset exemption threshold under the Home Mortgage Disclosure Act (HMDA) and a final rule increasing the asset exemption threshold for the Truth in Lending Act (TILA)...more

Ballard Spahr LLP

CFPB/Fed/OCC Increase Exemption Thresholds for Appraisal Requirement, Regs Z and M (UPDATED)

Ballard Spahr LLP on

The CFPB, Fed, and OCC have published notices in the Federal Register announcing that they are increasing three exemption thresholds that are subject to annual inflation adjustments....more

Ballard Spahr LLP

CFPB publishes annual CARD Act, HOEPA, QM adjustments

Ballard Spahr LLP on

The CFPB has published a final rule regarding various annual adjustments it is required to make under provisions of Regulation Z (TILA) that implement the CARD Act, HOEPA, and the ability to repay/qualified mortgage...more

Ballard Spahr LLP

CFPB adjusts HMDA data collection, TILA mortgage escrow thresholds

Ballard Spahr LLP on

In notices published in today’s Federal Register, the CFPB adjusted the thresholds of the asset-size exemptions for collecting HMDA data and establishing an escrow account for certain mortgage loans under TILA....more

Ballard Spahr LLP

CFPB/Fed/OCC increase exemption thresholds for appraisal requirement, Regs Z and M (UPDATED)

Ballard Spahr LLP on

The CFPB, Fed, and OCC have published notices in the Federal Register announcing that they are increasing three exemption thresholds that are subject to annual inflation adjustments. Effective January 1, 2018 through...more

Ballard Spahr LLP

CFPB announces annual adjustments to HMDA/TILA asset-size exemption thresholds

Ballard Spahr LLP on

The CFPB has announced annual adjustments to two asset-size exemption thresholds. First, the CFPB has made no change to the asset-size exemption threshold under HMDA/Regulation C which is currently set at $44 million. ...more

Ballard Spahr LLP

CFPB amends commentary on adjustments to exemption thresholds; makes no changes to 2017 thresholds

Ballard Spahr LLP on

The CFPB has adopted changes to its Reg Z commentary to memorialize the calculation methods used each year to adjust the thresholds for exempt consumer credit transactions and for transactions exempt from the special...more

Ballard Spahr LLP

CFPB Proposes Changes To Higher-Priced Mortgage Loan Exemption Threshold

Ballard Spahr LLP on

The Consumer Financial Protection Bureau (CFPB) published for comment proposed substantive and organizational changes to the Regulation Z Commentary regarding the calculation of the annual exemption threshold amount for the...more

Ballard Spahr LLP

CFPB Proposes Changes to Higher-Priced Mortgage Loans Exemption Threshold

Ballard Spahr LLP on

On August 4, 2016 the CFPB published for comment proposed substantive and organizational changes to the Regulation Z Commentary regarding the calculation of the annual exemption threshold  amount for the special appraisal...more

Ballard Spahr LLP

CFPB and Fed propose new Regs M and Z commentary on adjustments to exemption thresholds

Ballard Spahr LLP on

The CFPB and Federal Reserve Board have proposed amendments to their official Regulations Z and M staff commentaries to memorialize the calculation method used by the agencies each year to adjust the thresholds for exempt...more

BakerHostetler

CFPB Announces Dollar Threshold Adjustments to the Truth in Lending Act

BakerHostetler on

The Consumer Financial Protection Bureau (CFPB) recently released a final rule amending the dollar thresholds in Regulation Z, which implements the Truth in Lending Act (TILA). The CFPB’s final rule has two primary effects....more

Ballard Spahr LLP

CFPB publishes annual CARD Act, HOEPA and QM adjustments, corrects 2016 error

Ballard Spahr LLP on

The CFPB has published a final rule regarding various annual adjustments it is required to make under provisions of Regulation Z (TILA) that implement the CARD Act, HOEPA, and the ability to repay/qualified mortgage...more

Burr & Forman

Dodd-Frank News: January 2016: Dodd-Frank Wall Street Reform and Consumer Protection Act Update

Burr & Forman on

The Dodd-Frank Wall Street Reform and Consumer Protection Act was enacted as a measure to promote financial stability and protection for consumers through increased regulation of nearly every aspect of the consumer finance...more

Ballard Spahr LLP

Reduced HOEPA/QM points and fees limits; revisions to Reg Z small creditor/rural area definitions and asset test effective January...

Ballard Spahr LLP on

Since it is unusual for CFPB annual adjustments to result in reduced thresholds, we want to remind blog readers of the reduced HOEPA and QM points and fee limits that will be effective January 1, 2016. Effective January 1,...more

Ballard Spahr LLP

CFPB Makes No Change to Exemption Thresholds for Appraisal Requirement, Regs Z, M

Ballard Spahr LLP on

The CFPB has published notices in the Federal Register announcing that it is making no change to three exemption thresholds that are subject to annual inflation adjustments. Effective January 1, 2016, through December 31,...more

Ballard Spahr LLP

CFPB publishes annual CARD Act, HOEPA and QM adjustments

Ballard Spahr LLP on

The CFPB has published a final rule regarding various annual adjustments it is required to make under provisions of Regulation Z (TILA) that implement the CARD Act, HOEPA, and the ability to repay/qualified mortgage...more

Orrick - Finance 20/20

Fed and CFPB Announce Thresholds for Regulation Z and Regulation M Exempt Consumer Credit and Lease Transactions

Orrick - Finance 20/20 on

On September 9, the Fed and CFPB announced increases in the dollar thresholds in Regulation Z (Truth in Lending) and Regulation M (Consumer Leasing) for exempt consumer credit and lease transactions. These increases are...more

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