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ARTICLE · 05 DECEMBER 2016

Federal Agencies Issue Final Rules Adjusting Certain Credit Thresholds For Small Loans

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The Board of Governors of the FRB, the CFPB and the OCC issued a final rule detailing the method to be used to determine the threshold for exempting smaller mortgage loans...

United StatesFinance and Banking
Hogan Lovells Cadwalader
Hogan Lovells Cadwalader
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The Board of Governors of the Federal Reserve System ("FRB"), the Consumer Financial Protection Bureau ("CFPB") and the Office of the Comptroller of the Currency ("OCC") issued a final rule detailing the method to be used to determine the threshold for exempting smaller mortgage loans from the special appraisal requirements of the Truth in Lending Act ("TILA"). The current threshold will remain at $25,500, based on the Consumer Price Index for Urban Wage Earners and Clerical Workers ("CPI-W") that became effective on June 1, 2016.

The FRB and CFPB also issued a final rule detailing the method to be used to adjust the thresholds for exempting certain consumer credit and lease transactions from TILA and from the Consumer Leasing Act. The threshold for these exemptions will remain at $54,600 through 2017. As with the small mortgage loan threshold final rule, the calculation method adopted in the second final rule will allow the exemption thresholds to keep pace with the

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