CFPB makes annual adjustments to TILA thresholds
The CFPB Monday issued a final rule revising dollar amounts for certain regulations falling under Regulation Z that implement the Credit Card Accountability Responsibility and Disclosure Act (CARD Act), the Home Ownership and Equity Protection Act (HOEPA), and the ability-to-repay/qualified mortgage provisions of the Dodd-Frank Act. All adjustments will be effective Jan. 1, 2021.
The CFPB is required to annually adjust certain threshold amounts within various rules based on the percentage change in the consumer price index. Specifically, for open-end consumer credit plans under the Truth in Lending Act (TILA), the threshold that triggers requirements to disclose minimum interest charges will stay the same at $1 in 2021.
CARD Act penalty fee safe harbor
For open-end consumer credit plans under the CARD Act's amendments to TILA, the adjusted dollar amount in 2021 for the safe harbor for a first violation penalty fee will remain unchanged at $29. The adjusted dollar amount for the safe harbor for a subsequent violation penalty fee will also remain unchanged at $40.
For HOEPA loans, the adjusted total loan amount threshold for high-cost mortgages in 2021 will be $22,052. The adjusted points-and-fees dollar trigger for high-cost mortgages in 2021 will be $1,103.
Ability-to-repay and QM adjustments
For purposes of determining whether a covered transaction is a QM, the total points and fees charged may not exceed the threshold set for the size of the loan under the rule:
- for a loan amount of $110,260 or more, 3 percent of the total loan amount;
- for a loan amount of greater than or equal to $66,156 but less than $110,260, $3,308;
- for a loan amount of greater than or equal to $22,052 but less than $66,156, 5 percent of the total loan;
- for a loan amount of greater than or equal to $13,783 but less than $22,052, $1,103; and
- for a loan amount of less than $13,783, 8 percent of the total loan amount.
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