(Dec. 3, 2021) A regulatory alert on Truth in Lending (Regulation Z) annual threshold adjustments for various loans – which take effect Jan. 1 — was issued this week by NCUA, following up on action taken by the CFPB earlier this fall.
The NCUA alert (RA-21-10) notes that the adjustments for credit cards, closed-end home equity loans and qualified mortgages (QMs) are based on the annual percentage change reflected in the Consumer Price Index (CPI) as of June 1, 2021. CFPB is required to calculate the dollar amounts for several provisions in Reg Z each year.
In late October, the bureau increased many, but not all, of the threshold dollar amounts for the loans covered under Reg Z. No change in the $1 threshold triggering minimum interest charge disclosure requirements on open-end consumer credit plans was made, for example.
For open-end credit plans under the CARD Act, there were increases to $30 in the adjusted dollar amount for safe harbor for a first violation penalty fee and to $41 in the threshold for a subsequent violation penalty fee. For HOEPA loans, the adjusted total loan amount threshold for high-cost mortgages in 2022 will be $22,969, the agency said; the adjusted points-and-fees dollar trigger will be $1,148.
For QMs, the changes are a bit more complicated, with various thresholds for the spread between the annual percentage rate (APR) and the average prime offer rate (APOR) in 2022. The changes are detailed in the alert.
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(Aug. 27, 2021) Card issuers required to supply credit card agreement terms and other data to the CFPB must make all submissions via the agency’s Collect website (collect.consumerfinance.gov) beginning in January, according to a notice providing new technical specifications for submissions.
According to the bureau, the Collect website has been available since July 2018 for those participating in the semiannual Terms of Credit Card Plans (TCCP) Survey, and 83% of survey submissions early this year were made via Collect.
The bureau outlined the website in a notice published Monday in the Federal Register.
The credit card plan submissions are made by selected card issuers under requirements of the Truth in Lending Act (TILA) and the Credit Card Accountability Responsibility and Disclosure Act (CARD Act). Submissions include the semiannual Terms of Credit Card Plan (TCCP) Survey; quarterly credit card agreements; and annual reports related to college credit card marketing agreements and data.
In an email late last week, the bureau said card issuers will be required to use the Collect website for the following submissions on the dates noted and after:
(1) TCCP Survey data (for the Feb. 14, 2022), deadline,
(2) quarterly credit card agreement submissions (for the Jan. 31, 2022, deadline), and
(3) annual reports related to college credit card marketing agreements and data (for the March 31, 2022, deadline).
Issuers have until Nov. 1 of this year to register for Collect; those that have registered before to submit their TCCP Survey data will not need to register again.
To register, the bureau said, fill out and email the Collect registration form to [email protected]. (Download he registration form here.) Once card issuers receive their login credentials, starting on Dec. 1, they will be able to review their current submissions and make the required submissions for the fourth quarter of calendar year 2021 using Collect, the CFPB said.
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