Banking agencies announce 2024 regulatory thresholds

The Consumer Financial Protection Bureau, Federal Reserve and Office of the Comptroller of the Currency today announced that the 2024 threshold for whether higher-priced mortgage loans are subject to special appraisal requirements will increase from $31,000 to $32,400. At the same time, the Fed and CFPB announced an increase in the dollar thresholds used to determine whether certain consumer credit and lease transactions in 2024 are subject to certain Regulation Z (truth in lending) and Regulation M (consumer leasing) requirements.

The Dodd-Frank Act added special appraisal requirements for higher-priced mortgage loans, including that creditors obtain a written appraisal based on a physical visit to the interior of the home before making a higher-priced mortgage loan, according to the Fed. The rules implementing these requirements contain an exemption for loans of $25,000 or less, adjusted annually to reflect CPI-W increases. The new threshold amount will be effective January 1, 2024.

The 2024 thresholds for Regulation Z and Regulation M both will apply to consumer credit transactions and consumer leases of $69,500 or less, up from the current threshold of $66,400. However, private education loans and loans secured by real property, such as mortgages, are subject to Regulation Z regardless of the amount of the loan.

In related news, the CFPB announced it is amending Regulation V, which implements the Fair Credit Reporting Act, to establish the maximum allowable charge for disclosures by a consumer reporting agency to a consumer for 2024. The maximum allowable charge will be $15.50 next year.

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