Bureau issues TIL annual threshold adjustments

The CFPB has published [82 FR 41158] in today's Federal Register a final rule amending the official interpretations for Regulation Z, which implements the Truth in Lending Act (TILA). The rule revises, as applicable, the dollar amounts for provisions implementing TILA and amendments to TILA. Specifically—

• For open-end consumer credit plans under TILA, the threshold that triggers requirements to disclose minimum interest charges will remain unchanged at $1.00 in 2018.
• For open-end consumer credit plans under the CARD Act amendments to TILA, the adjusted dollar amount for the safe harbor for a first violation penalty fee will remain unchanged at $27 in 2018 and the adjusted dollar amount for the safe harbor for a subsequent violation penalty fee will remain unchanged at $38 in 2018.
• For HOEPA loans, the adjusted total loan amount threshold for high-cost mortgages in 2018 will be $21,032. The adjusted points and fees dollar trigger for high-cost mortgages in 2018 will be $1,052.
• For the general rule to determine consumers’ ability to repay mortgage loans, the maximum thresholds for total points and fees for qualified mortgages in 2018 will be
  • 3 percent of the total loan amount for a loan greater than or equal to $105,158;
  • $3,155 for a loan amount greater than or equal to $63,095 but less than $105,158;
  • 5 percent of the total loan amount for a loan greater than or equal to $21,032 but less than $63,095;
  • $1,052 for a loan amount greater than or equal to $13,145 but less than $21,032; and
  • 8 percent of the total loan amount for a loan amount less than $13,145.

The rule will be effective January 1, 2018. The new interpretations paragraphs have been added to sections 1026.32, .43 and .52 in BankersOnline's Regulations pages for Regulation Z.