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

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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, 2016, these exemption thresholds remain as follows:

  • Smaller loans exempt from the appraisal requirement for “higher priced mortgage loans,” $25,500
  • Consumer credit transactions exempt from Truth in Lending Act/Regulation Z, $54,600 (but loans secured by real property or personal property used or expected to be used as a consumer’s principal dwelling and private education loans are covered regardless of amount)
  • Consumer leases exempt from Consumer Leasing Act/Regulation M, $54,600

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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