The Consumer Financial Protection Bureau (CFPB) announced on September 18 an update to the annual dollar amount thresholds under the Truth in Lending Act (TILA) and Home Mortgage Disclosure Act (HMDA). This update contained a final rule that revised dollar amounts for provisions per the implementation of TILA and its amendments. The impacted areas notably include loans approved under the Home Ownership and Equity Protection Act of 1994 (HOEPA) and qualified mortgages (QM).
The CFPB is legally mandated to adjust annual dollar amounts in various provisions within Regulation Z. The basis of these adjustments is the annual percentage change reflected in the Consumer Price Index for Urban Wage Earners and Clerical Workers.
For any legal professionals working in large corporations or leading law firms, this update could have significant implications for your practice or compliance programs. It is crucial to understand the details of these adjustments and how they may influence your organization’s operations or client services.
You can access the revised rule via JD Supra, as provided by Orrick, Herrington & Sutcliffe LLP. We recommend thoroughly reviewing the revised regulations and assessing the potential changes they could introduce in your legal and procedural frameworks.
As we continue to navigate the evolving regulatory landscape, please stay attuned to these important changes and adjustments. The continuous legal updates and adjustments from bodies like the CFPB highlight the importance of remaining adaptable in the rapidly changing world of law.