Federal Reserve and CFPB Propose Method for Adjusting TILA and Consumer Leasing Act Exemption Thresholds

CFPB TILA Federal Reserve Consumer Leasing Act

On July 22, the CFPB and the Federal Reserve released  proposed rules detailing the method for adjusting the dollar thresholds in Regulation Z (TILA) and Regulation M (Consumer Leasing Act/CLA) for exempt consumer credit and lease transactions. Pursuant to the Dodd-Frank Act, the exemption thresholds in TILA and the CLA are adjusted annually based on the percentage increase in the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W). The recently released proposals seek to clarify, among other things, that in the years following a year in which there is no annual percentage increase in the CPI-W, the CFPB and Federal Reserve will not adjust the exemption thresholds. Comments on the proposals are due within 30 days of publication in the Federal Register.