Updated Exemption Thresholds for Consumer Credit Transactions and Higher-Priced Mortgage Loan Appraisals

In Client and Friends Memos by BMG Memorandum

In the October 30, 2019, issue of the Federal Register (84 FR 58020), the Board of Governors of the Federal Reserve System (“Board”) and the Bureau of Consumer Financial Protection (“CFPB”) published final rules increasing the threshold for consumer credit transactions exempt from the Truth In Lending Act. Also in the October 30, 2019, issue of the Federal Register (84 FR 58013), the Board, the CFPB and the Office of the Comptroller of the Currency, Treasury (“OCC”) published final rules increasing the threshold exemption from required appraisals for higher-priced mortgage loans. In both instances, the final rules will take effect on January 1, 2010.

Full Memorandum