New thresholds set for TILA protections, appraisal requirements

CFPB
Samuel Corum/Bloomberg

Federal regulators raised the threshold at which certain financial products are subject to enhanced oversight standards by a smaller percentage than last year as inflation eased.

The Federal Reserve and the Consumer Financial Protection Bureau raised the price at which consumer credit and leasing transactions are subject to truth-in-lending requirements from $69,500 to $71,900.

The Office of the Comptroller of the Currency joined the Fed and the CFPB in raising the price at which mortgages are exempt from appraisal requirements from $32,400 to $33,500.

The Truth in Lending Act of 1968, also known as TILA, requires that consumers be informed about the terms and costs related to certain financial products. The law brought standardization to lending products — including the uniform use of annual percentage rate for consumer-facing credit and loans. The act also establishes the conditions under which consumers can rescind agreements that pose excessive risks.

Originally, oversight of consumer protections within the act were assigned to the Fed, but the law was modified by the Dodd-Frank Act of 2010, which created the CFPB and granted it authority over TILA oversight and enforcement.

Dodd-Frank also required the agencies to update the minimum threshold at which products are subject to TILA based on inflation. The agencies use the Bureau of Labor Statistics Consumer Price Index for Urban Wage Earners and Clerical Workers, or CPI-W, as their benchmark for price adjustments. This year, the index increased 3.4%. The prices are also rounded to the closest $100 increment.

TILA also requires special appraisals for high-risk mortgages, known as higher-priced mortgage loans, or HPMLs. Originally, the threshold for these appraisals was set at $25,000, but it too has been raised annually based on inflation.

The agencies' implementation of these laws is known as Regulation Z. Unlike other, more comprehensive rule changes, regulators are not required to go through a notice and comment process to update the thresholds set by Regulation Z, because its authorizing legislation calls for annual updates. 

The new price thresholds go into effect next year.

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Politics and policy Regulation and compliance Federal Reserve CFPB
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