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. You are advised that the above increases in the threshold amount for exempt consumer credit transactions do not apply to consumer credit transactions secured by real property or by personal property used or expected to be used as the principal dwelling of the consumer – i.e., these consumer credit transactions are always subject to Regulation Z. HOEPA Loan Points and Fees Certain closed-end consumer credit transactions secured by the consumer’s principal dwelling are subject to the requirements of §226.32 of Regulation Z (HOEPA loans) if the total points and fees payable by the consumer at or before loan consummation exceed the greater of $592 (the amount for 2011) or 8 percent of the total loan amount. The FRB is required to adjust annually this dollar amount based on the annual percentage change reflected in the Consumer Price Index as reported on June 1. Effective January 1, 2012, the FRB is adjusting this dollar amount for 2012 to $611 by amending comment 32(a)(1)(ii)-2 of the Official Staff Commentary to Regulation Z.