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Financial Services Law Insights and Observations

Agencies finalize TILA, CLA 2022 thresholds

Agency Rule-Making & Guidance CFPB Federal Reserve TILA Consumer Leasing Act Regulation Z Regulation M Bank Regulatory Dodd-Frank

Agency Rule-Making & Guidance

On December 1, the CFPB and the Federal Reserve Board finalized the annual dollar threshold adjustments that govern the application of TILA (Regulation Z) and the Consumer Leasing Act (Regulation M) (available here and here), as required by the Dodd-Frank Act. The exemption threshold for 2021, based on the annual percentage increase in the Consumer Price Index for Urban Wage Earners and Clerical Workers, will increase from $58,300 to $61,000, except for private education loans and loans secured by real or personal property used or expected to be used as the principal dwelling of a consumer, which are subject to TILA regardless of the amount. The final rules takes effect January 1, 2022.