CFPB Issues Annual Threshold Adjustments for TILA (Regulation Z)

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The CFPB recently amended TILA’s implementing Regulation Z by updating the dollar amounts of various thresholds for several provisions that are adjusted annually.  The threshold adjustments will be effective January 1, 2021.

For open-end consumer credit plans under TILA the threshold triggering disclosure of 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 harbors for both a first violation penalty fee and a subsequent violation penalty fee remain unchanged at $29 and $40, respectively.

For HOEPA loans, the adjusted total loan amount threshold for high-cost mortgages will increase by $72 to $22,052. The adjusted points-and-fees dollar trigger for high-cost mortgages will increase by $4 to $1,103.

For qualified mortgages and determining a consumer’s ability to repay, the maximum thresholds for total points and fees will increase as follows:

  • 3 percent of the total loan amount for a loan greater than or equal to $110,260;
  • $3,308 for a loan amount greater than or equal to $66,156 but less than $110,260;
  • 5 percent of the total loan amount for a loan greater than or equal to $22,052 but less than $66,156;
  • $1,103 for a loan amount greater than or equal to $13,783 but less than $22,052; and
  • 8 percent of the total amount for a loan amount less than $13,783.

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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