The Consumer Financial Protection Bureau and other federal agencies have announced thresholds for certain regulations for 2020. This includes for higher-priced mortgage loans made during calendar year 2020 and Regulations Z and M for consumer credit and lease transactions.
The threshold for exempting loans from special appraisal requirements for higher-priced mortgage loans during 2020 will increase to $27,200 in 2020, up from $26,700, effective Jan. 1. This is based on the annual percentage increase in the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W) as of June 1, 2019.
The CPI-W also determines the dollar thresholds for determine exempt consumer credit and lease transactions under Regulation Z (which regulates the Truth in Lending Act) and Regulation M (which regulates the Consumer Leasing Act).
The protections of Regulations Z and M in 2020 will generally apply to consumer credit transactions and consumer leases of $58,300 or less in 2020.
This does not apply to private education loans and loans secured by real property, whicha re subject to the Truth In Lending Act regardless of loan amount.
In addition to the CompBlog, CUNA’s Compliance Community contains discussion boards and a number of other resources for credit union compliance professionals around the country.