On November 25, 2015, the Consumer Financial Protection Bureau (CFPB), Federal Reserve Board, and Office of the Comptroller of the Currency (OCC) announced that the threshold for exempting loans from special appraisal requirements for higher-priced mortgage loans will not change in 2016. The threshold remains $25,500.
The threshold is based on the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W). When there is no annual percentage increase in the CPI-W, the agencies do not adjust the exemption threshold from the prior year.
Regulation Z and M Exemptions
The Federal Reserve Board and the CFPB published the dollar thresholds in Regulation Z (Truth in Lending (TILA)) and Regulation M (Consumer Leasing Act (CLA)) that will apply for determining exempt consumer credit and lease transactions in 2016.
The TILA and the CLA generally will apply to consumer credit transactions and consumer leases of $54,600 or less in 2016—the same thresholds that applied in 2015. However, private education loans and loans secured by real property (such as mortgages) are subject to the TILA regardless of the amount of the loan.
For more information, please contact Venable's CFPB Task Force.