Fed, CFPB Update Dollar Thresholds on Reg Z, Reg M

WASHINGTON—The Federal Reserve Board and the Consumer Financial Protection Bureau announced the dollar thresholds used to determine whether certain consumer credit and lease transactions in 2024 are subject to certain Regulation Z (Truth in Lending) and Regulation M (Consumer Leasing) requirements.

Specifically, based on the annual percentage increase in the CPI-W as of June 1, 2023, Regulation Z and Regulation M generally will apply to consumer credit transactions and consumer leases of $69,500 or less in 2024, according to the agencies.

However, private education loans and loans secured by real property, such as mortgages, are subject to Regulation Z regardless of the amount of the loan, the agencies explained.

Read the Consumer Leasing (Regulation M).

Read the Truth in Lending (Regulation Z).

Mortgage Thresholds

Separately, the agencies also announced the 2024 threshold for whether higher-priced mortgage loans are subject to special appraisal requirements will increase from $31,000 to $32,400.

The threshold amount will be effective Jan. 2024, and is based on the annual percentage increase in the Consumer Price Index for Urban Wage Earners and Clerical Workers, known as CPI-W, as of June 1, 2023, the agencies said.

As the agencies noted in releasing the update, the Dodd-Frank Act added special appraisal requirements for higher-priced mortgage loans, including that creditors obtain a written appraisal based on a physical visit to the interior of the home before making a higher-priced mortgage loan. The rules implementing these requirements contain an exemption for loans of $25,000 or less, adjusted annually to reflect CPI-W increases, the agencies added.

Read the Appraisals for Higher-Priced Mortgage Loans Exemption Threshold.

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