The Federal Reserve Board and the Consumer Financial Protection Bureau jointly issued an increase in the exemption thresholds, which are tied to the Consumer Price Index, for Regulation Z and Regulation M exemptions. Loans or leases at or below the thresholds are subject to regulatory protections.
The regulators have released the new index limit for 2019 used in setting the threshold effective January 1, 2019. The new limit is $57,200 which is up from $55,800 in 2018. The protections of the Truth in Lending Act and the Consumer Leasing Act generally will apply to consumer credit transactions and consumer leases of $57,200 or less in 2019, an increase from last year.
Keep in mind that private education loans and loans secured by real property (such as mortgages) are subject to the Truth in Lending Act regardless of the loan amount.
Ensure your loan origination systems and staff training are updated in time to enact the change.
New Threshold Amounts for 2019 under Regulation Z HPML Appraisal Requirements
The Office of the Comptroller of the Currency (OCC), Federal Reserve Bank (FRB) and Consumer Financial Protection Bureau (CFPB) released the revised exemption amount which goes into effect on January 1, 2019 for the appraisal threshold for higher priced mortgage loans (HPML). The limit began at $25,000 and is adjusted annually for inflation. The figure for 2019 is now $26,700, which is up $700 from 2018. Loans which may be HPML’s with dollar amounts below this figure would be exempt from the requirement to obtain a written appraisal from a certified or licensed appraiser.
TCA®, A Better Way provides you with regulatory information from a compliance professional’s viewpoint. Contact us at (800) 934‐7347 or [email protected] if you have any questions!