News & Analysis as of

Exemptions 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)

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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...

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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

Ballard Spahr LLP

CFPB Finalizes Rule to Implement Growth Act Escrow Exemption for Higher-Priced Mortgage Loans

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As previously reported, the Economic Growth, Regulatory Relief, and Consumer Protection Act (Growth Act), passed in June 2018, created an exemption from the requirement to maintain an escrow account in connection with a...more

Ballard Spahr LLP

CFPB Adjusts HMDA and TILA Asset Exemption Thresholds

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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 Proposes to Implement Growth Act Escrow Exemption for Higher-Priced Mortgage Loans

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As previously reported, the Economic Growth, Regulatory Relief, and Consumer Protection Act (Growth Act), also known as S.2155, directs the CFPB to implement an exemption from the mandatory escrow account requirement for...more

Ballard Spahr LLP

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

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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

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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

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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

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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

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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

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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

Ballard Spahr LLP

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

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

Foley & Lardner LLP

Truth in Lending Act and Consumer Leasing Act Dollar Thresholds Raised: Fewer Transactions Exempt

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More consumer credit and leasing transactions will be subject to the Truth in Lending Act (TILA) and Consumer Leasing Act (CLA) in 2015. Effective January 1, 2015, the dollar threshold for exemption of most consumer...more

Ballard Spahr LLP

CFPB adjusts HMDA data collection and TILA mortgage escrow thresholds

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In notices published in yesterday’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

Williams Mullen

CFPB Issues Final Rules, Interpretations and Commentary to Adjust the Exemption Threshold to Regulations M and Z

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On Monday, November 25, 2013, the Consumer Financial Protection Bureau (the “Bureau”) issued final rules amending its Regulation Z (Truth In Lending) and Regulation M (Consumer Leasing) in accordance with the requirements of...more

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