The CFPB has published a final rule regarding various annual adjustments it is required to make under provisions of Regulation Z (TILA) that implement the CARD Act, HOEPA, and the ability to repay/qualified mortgage provisions of Dodd-Frank.  The adjustments reflect changes in the Consumer Price Index in effect on June 1, 2016 and will take

Since it is unusual for CFPB annual adjustments to result in reduced thresholds, we want to remind blog readers of the reduced HOEPA and QM points and fee limits that will be effective January 1, 2016.

Effective January 1, the lower limits will be:

  • The total loan amount thresholds that determine whether a transaction is

The CFPB has published a final rule regarding various annual adjustments it is required to make under provisions of Regulation Z (TILA) that implement the CARD Act, HOEPA, and the ability to repay/qualified mortgage provisions of Dodd-Frank.  The adjustments made by the final rule are effective January 1, 2016.

The CARD Act requires the CFPB

In July, the CFPB proposed amendments to Regulation Z (TILA) and Regulation X (RESPA) to implement various provisions of the Dodd-Frank Act.   Those proposals included an expansion of the definition of “finance charge” to include additional charges, and a new test for determining when a mortgage meets the APR trigger for a “high-cost mortgage”