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The CFPB, Fed, and OCC have announced that they are increasing three exemption thresholds that are subject to annual inflation adjustments.  Effective January 1, 2024 through December 31, 2024, these exemption thresholds are increased as follows:

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The CFPB, Fed, and OCC have published notices in the Federal Register announcing that they are increasing three exemption thresholds that are subject to annual inflation adjustments.  Effective January 1, 2018 through December 31, 2018, these exemption thresholds are increased as follows:

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Last month, a bipartisan group of 70 Senators were signatories to a letter sent to Director Cordray urging the CFPB to “carefully tailor its regulations to match the unique nature of community banks and credit unions.”  In their letter, the Senators referenced Dodd Frank Section 1022(b)(3)(A) which allows the CFPB to create exemptions from its rules for any class of covered persons, service providers, or consumer financial products or services as the CFPB “determines necessary or appropriate to carry out the purposes and objectives” of the Consumer Financial Protection Act after taking into consideration certain specified factors. … Continue Reading

The CFPB has announced annual adjustments to two asset-size exemption thresholds.  First, the CFPB is making no change to the asset-size exemption threshold under HMDA/Regulation C which is currently set at $44 million.  Banks, savings associations, and credit unions with assets at or below $44 million as of December 31, 2015 will continue to be exempt from collecting HMDA data in 2016.… Continue Reading

The CFPB has published notices in the Federal Register announcing that it is making no change to three exemption thresholds that are subject to annual inflation adjustments.  Effective January 1, 2016 through December 31, 2016, these exemption thresholds remain as follows:

  • Smaller loans exempt from the appraisal requirement for “higher priced mortgage loans,” $25,500
  • Consumer credit transactions exempt from Truth in Lending Act/Regulation Z, $54,600 (but loans secured by real property or personal property used or expected to be used as a consumer’s principal dwelling and private education loans are covered regardless of amount)
  • Consumer leases exempt from Consumer Leasing Act/Regulation M, $54,600

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Adjustments to two asset-size exemption thresholds were published by the CFPB in today’s Federal Register.  First, the CFPB has increased the asset-size exemption threshold under HMDA/Regulation C which is currently set at $43 million.  Banks, savings associations, and credit unions with assets at or below $44 million as of December 31, 2014 are exempt from collecting HMDA data in 2015.… Continue Reading

On November 16, the CFPB adopted a temporary exemption for certain mortgage disclosure requirements added by the Dodd-Frank Act to allow the disclosures to be implemented along with the proposal to integrate the Real Estate Settlement Procedures Act and Truth in Lending Act disclosures.  Without the temporary exemption, industry would have been required to begin providing the new disclosures as of January 21, 2013.… Continue Reading