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. Recall that effective July 21, 2011, the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) amended the Truth in Lending Act by increasing the threshold for exempt consumer credit transactions from $25,000 to $50,000 and requiring that, on or after December 31, 2011, this threshold be adjusted annually. See this firm’s April 5, 2011 memorandum discussing this Dodd-Frank Act amendment, which is posted on our web site at www.bmandg.com. Accordingly, the FRB and the CFPB are adjusting the exemption threshold to $53,000, effective January 1, 2013. You are advised that the threshold amount for exempt consumer credit transactions does not apply to the following consumer credit transactions: (1) a consumer credit transaction secured by (i) any real property, or (ii) personal property that is used or expected to be used as the consumer’s principal dwelling; and, (2) a private education loan. These loans remain subject to Regulation Z regardless of the amount of credit extended or to be extended under these loans.

Complete Memorandum