When the Truth in Lending Act became law in 1969, the Federal Reserve Board soon thereafter promulgated its implementing regulation, Regulation Z.  For many years, the Fed would respond to questions about TILA and Reg. Z orally over the phone or in writing through the issuance of unofficial staff letters and, infrequently, official staff letters. … Continue Reading

The CFPB and Federal Reserve Board have proposed amendments to their official Regulations Z and M staff commentaries to memorialize the calculation method used by the agencies each year to adjust the thresholds for exempt consumer credit transactions and consumer leases.

Both the CFPB’s and Fed’s Regulations Z and M and their accompanying commentaries provide that the exemption thresholds will be adjusted annually effective January 1 of each year based on any annual percentage increase in the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W) that was in effect on the preceding June 1. … Continue Reading