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Financial Services Law Insights and Observations

CFPB Adjusts CARD Act, HOEPA Thresholds

Credit Cards CFPB Mortgage Origination CARD Act

Consumer Finance

On December 16, the CFPB published a final rule to review and adjust provisions of Regulation Z that implement amendments to TILA under the CARD Act and HOEPA. Specifically, the CFPB is required to adjust, as appropriate based on the annual percentage change reflected in the Consumer Price Index in effect on June 1, 2013, (i) the threshold amount that triggers requirements for the disclosure of minimum interest charges and (ii) the maximum penalty fee card issuers can impose for violating account terms without violating the restrictions on penalty fees established by the CARD Act. For 2014, the minimum interest charge disclosure threshold will remain unchanged, while the permissible penalty fees will increase to $26 for a first late payment and $37 for each subsequent violation within the following six months. Similarly, the CFPB is required to adjust the combined points and fees threshold that triggers compliance with HOEPA. Effective January 1, 2014, that threshold will be $632.