Amy K’s Compliance Corner
Regulation Z §1026.3 describes the transactions that are exempt from Regulation Z, which exemption include credit over the applicable threshold amount. The Dodd-Frank Act requires that this threshold be adjusted annually for inflation by the annual percentage increase in the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI–W), as published by the Bureau of Labor Statistics. Therefore for January 1, 2013 through December 31, 2013, the threshold amount is $53,000. This final rule is effective January 1, 2013, and can be found at this link: http://www.gpo.gov/fdsys/pkg/FR-2012-11-21/pdf/2012-27993.pdf
The Consumer Financial Protection Bureau also issued a final rule amending Regulation Z in reference to the dollar amount that triggers requirements for certain home mortgage loans bearing fees above a certain amount, which also is required to be adjusted annually. The Home Ownership and Equity Protection Act of 1994 (HOEPA) sets forth rules for home-secured loans in which the total points and fees payable by the consumer at or before loan consummation exceed the greater of $400 or 8 percent of the total loan amount. The CPFB has adjusted the $400 amount based on the annual percentage change reflected in the Consumer Price Index as reported on June 1, 2012. The adjusted dollar amount for 2013 is $625, reflecting a 2.3 percent increase in the CPI–U from June 2011 to June 2012, rounded to the nearest whole dollar.
This final rule is effective January 1, 2013, and can be found at this link:
Finally, a final rule was also issued amending Regulation M which implements the Consumer Leasing Act. The Dodd-Frank Act also requires that this threshold be adjusted annually by any annual percentage increase in the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI–W). Therefore, the threshold amount from January 1, 2013 through December 31, 2013, the threshold amount is $53,000.
This final rules is also effective January 1, 2013, and can be found at this link:
Should you have any questions or concerns on this or any other compliance issue, please do not hesitate to contact Amy Kleinschmit at email@example.com or 701.214.9721.