On November 13, the Consumer Financial Protection Bureau (CFPB) and the Federal Reserve Board (Fed) announced increased dollar thresholds used to determine whether certain consumer credit and lease transactions in 2024 are exempt from Regulation Z (Truth in Lending) and Regulation M (Consumer Leasing).
Specifically, based on the annual percentage increase in the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W), Regulation Z and Regulation M generally will apply to consumer credit transactions and consumer leases of $69,500 or less, in 2024, compared to $66,400 in 2023. Transactions at or below the thresholds are subject to regulation protection. However, private education loans and loans secured by real property, such as mortgages, are subject to Regulation Z regardless of the loan amount. This threshold is also important at the state level, as several states tie the applicability thresholds for their own credit laws to the Regulation Z threshold.
The CFPB, Fed, and Office of the Comptroller of the Currency also announced that the 2024 threshold for exempting loans from special appraisal requirements will increase from $31,000 to $32,400. The Dodd–Frank Act added special appraisal requirements for higher-priced mortgage loans, including requiring that creditors obtain a written appraisal based on a physical visit to the home interior before making a higher-priced mortgage loan. The rules implementing these requirements contain an exemption for loans of $25,000 or less, adjusted annually to reflect CPI-W increases.