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Financial Services Law Insights and Observations

Agencies adjust threshold for Regulations Z and M

Agency Rule-Making & Guidance CFPB Federal Reserve Federal Register TILA Consumer Leasing Act Regulation M Regulation Z

Agency Rule-Making & Guidance

On October 31, the CFPB and the Federal Reserve Board finalized the annual dollar threshold adjustments that govern the application of Regulation Z (Truth in Lending Act) and Regulation M (Consumer Leasing Act) to credit transactions, as required by the Dodd-Frank Act (published in the Federal Register here and here). Each year the thresholds must be readjusted based on the annual percentage increase in the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W). The exemption threshold for 2020, based on the annual percentage increase in the CPI-W, is now $58,300 or less, except for private student loans and loans secured by real property, which are subject to TILA regardless of the amount.