Alert notes increasing Reg Z, M thresholds, Reg V fees

(Jan. 7, 2022) A regulatory alert calling attention to threshold and fee adjustments – which are increasing for the new year — under truth in lending, consumer leasing and fair credit reporting regulations by the CFPB was distributed last week by NCUA.

The alert, sent to all federally insured credit unions, notes that last month the bureau issued final annual adjustments for the exemption thresholds outlined under the Truth in Lending Act (TILA or Regulation Z) and the Consumer Leasing Act (CLA or Regulation M). The alert also points out that CFPB issued an annual adjustment to the maximum amount credit bureaus may charge consumers for making a file disclosure to a consumer under the Fair Credit Reporting Act (FCRA or Regulation V).

More specifically:

  • The Reg Z threshold (for appraisals for higher-priced mortgage loan exemptions) will increase to $28,500 from $27,200.
  • The Reg M threshold (for consumer credit and consumer lease exemptions) will increase to $61,000 from $58,300.
  • The Reg V ceiling (for credit bureau consumer report fees) will increase to $13.50 from $13.

The Reg Z and Reg M threshold changes are based on the annual increase in the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W) in effect as of June 1, 2021. The Reg V ceiling is based on the CPI for all urban consumers.

LINK:

NCUA Regulatory Alert 21-RA-11: 2022 Threshold Adjustments Under the Truth in Lending Act (Regulation Z), the Consumer Leasing Act (Regulation M), and the Fair Credit Reporting Act (Regulation V)