Search Results

In the August 30, 2017, issue of the Federal Register (82 FR 41158, click here), the Consumer Financial Protection Bureau established the following 2018 thresholds for high-cost and qualified mortgages under §§1026.32 and 1026.43, respectively.

In the August 15, 2014 issue of the Federal Register (79 FR 48015), the Consumer Financial Protection Bureau established the following 2015 thresholds for high-cost and qualified mortgages under §§1026.32 and 1026.43, respectively.

Threshold Amount Raised for Exempt Transactions under Regulation Z In the November 21, 2012, issue of the Federal Register (77 FR 69736 – click here) the Board of Governors of the Federal Reserve System (FRB) and the Consumer Financial Protection Bureau (CFPB) published final rules amending the official interpretation and commentary to Regulations Z by increasing the threshold for exempt consumer credit transactions to $53,000, effective January 1, 2013.

On August 15, 2012, this firm issued a memorandum (click here) on the proposed rule to amend the HOEPA Loan Coverage in §1026.32(a)(1)(i) and (b)(1)(i) of Regulation Z, which was published in the August 15, 2012 issue of the Federal Register by the Consumer Financial Protection Bureau (CFPB). The proposed rule’s comment period for this amendment was originally stated to end on September 7, 2012. The CFPB has reconsidered and in yesterday’s issue of the Federal Register (77 FR 54844) published a notice that it is extending the comment period for the proposed amendments to §1026.32(a)(1)(i) and (b)(1)(i) to November 6, 2012.

In the June 20, 2011 issue of the Federal Register the Federal Reserve Board (FRB) published final rules increasing the threshold amounts for the following transactions: Exempt Consumer Credit Transactions Effective July 21, 2011, the Dodd-Frank Act amends TILA by increasing the threshold amount for exempt consumer credit transactions from $25,000 to $50,000 (see §226.3(b) of Regulation Z). In addition, the Dodd-Frank Act requires that this threshold be adjusted annually by any annual percentage increase in the Consumer Price Index for Urban Wage Earners and Clerical Workers. (See our April 5, 2011 memorandum at http://www.bmandg.com/). Effective January 1, 2012, the FRB is adjusting the exemption threshold under §226.3(b) for 2012 from $50,000 to $51,800, based on the annual percentage increase in the above CPI-W as of June 1, 2011, by adding new paragraph 1.iii to comment 3(b) of the Official Staff Commentary to Regulation Z.

On July 30, 2008, the Board of Governors of the Federal Reserve System (“Board”) published in the Federal Register (pages 44522 – 44614) its final rule (the “final rule”) amending Regulation Z and its Official Staff Interpretations in Supplement I to Regulation Z (“Interpretations”). This memorandum will address only that part of the final rule that amends Sections 226.32(d)(7), 226.34(a)(4), and adds new Section 226.35, which relate to HOEPA loans and higher-priced mortgage loans. These amendments become effective October 1, 2009, except for the property tax and insurance escrow requirement of Section 226.35(b)(3) (see page 16 for an explanation).