The CFPB recently amended the implementing regulations for TILA Z by updating the dollar amounts of various thresholds for several provisions that are adjusted annually. The new threshold adjustments will take effect on January 1, 2022.

For indefinite consumer credit plans under TILA, the threshold for minimum interest charge disclosure will remain unchanged at $ 1.00.

For indefinite consumer credit plans under the CARD changes made by TILA, the adjusted dollar amount for safe zones for first violation penalty fee and subsequent violation penalty fee will increase. of $ 1, to reach $ 30 and $ 41, respectively.

For HOEPA loans, the threshold for the adjusted total loan amount for high cost mortgages will be increased from $ 22,052 to $ 22,969. And the dollar-adjusted point and fee trigger for high cost mortgages will drop from $ 1,103 to $ 1,148.

The thresholds for meeting the general definition of qualifying mortgage loans will also increase. Specifically, to meet the general definition of qualified mortgages, the APR cannot exceed the Average Prime Rate (APR) for a transaction comparable to the date the interest rate is set by the following amounts:

  • 2.25 percentage points or more for a senior loan with a loan amount greater than or equal to $ 114,847;
  • 3.5 percentage points or more for a senior loan where the loan amount is greater than or equal to $ 68,908 but less than $ 114,847;
  • 6.5 percentage points or more for a senior loan with a loan amount of less than $ 68,908;
  • 6.5 percentage points or more for a first loan secured by a manufactured home with a loan amount of less than $ 114,847;
  • 3.5 percentage points or more for a subordinated lien loan where the loan amount is greater than or equal to $ 68,908; and
  • 6.5 percentage points or more for a subordinated loan amount less than $ 68,908.

For all categories of qualifying mortgages, the maximum thresholds for total points and fees will increase as follows:

  • 3 percent of the total loan amount for a loan greater than or equal to $ 114,847;
  • $ 3,445 for a loan amount greater than or equal to $ 68,908 but less than $ 114,847;
  • 5 percent of the total loan amount for a loan greater than or equal to $ 22,969 but less than $ 68,908;
  • $ 1,148 for a loan amount greater than or equal to $ 14,356 but less than $ 22,969; and
  • 8 percent of the total loan amount for a loan amount less than $ 14,356.

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