Agencies Propose Calculation for TILA, Consumer Leasing Act Exemptions

The Federal Reserve Board, Office of the Comptroller of the Currency and Consumer Financial Protection Bureau today issued a joint proposal for calculating adjustments to the exemption thresholds for certain consumer credit and lease transactions from the Truth in Lending Act and the Consumer Leasing Act. The Dodd-Frank Act requires that these exemption thresholds be recalculated annually to keep pace with the Consumer Price Index for Urban Wage Earners and Clerical Workers.

The Fed and CFPB also proposed a method for adjusting the exemption threshold for small loans from the higher-priced mortgage loan requirements under TILA. Under Dodd-Frank, loans of $25,000 or less are not required to obtain a written appraisal based on a physical visit to the home’s interior. The proposed calculation would allow the threshold to be adjusted annually for inflation. Comments on the proposals will be accepted for 30 days after publication in the federal register.