CFPB Releases Annual Threshold Adjustments for Regulation Z
Adjustments go into effect Jan. 1.
The Consumer Financial Protection Bureau (CFPB) released the annual threshold adjustments for Regulation Z.
The adjustments will be effective Jan. 1, 2020, and are as follows:
- Credit Card Safe Harbor Penalty fees under 1026.52 increases to $29 and subsequent violation penalty fee increases to $40;
- HOEPA Loan threshold for the transactions’ total points and fees will increase to $21,980, and the points and fees dollar trigger will increase to $1,099; and
- For qualified mortgages, which provide creditors with certain protections from liability under the Ability-to-Repay Rule, the maximum thresholds for total points and fees in 2020 will be 3% of the total loan amount for a loan greater than or equal to $109,898; $3,297 for a loan amount greater than or equal to $65,939 but less than $109,898; 5% of the total loan amount for a loan greater than or equal to $21,980 but less than $65,939; $1,099 for a loan amount greater than or equal to $13,737 but less than $21,980; and 8% of the total loan amount for a loan amount less than $13,737.
Question of the Week
Q. The Consumer Financial Protection Bureau and the Federal Reserve recently issued a final rule amending Regulation CC, which implements the Expedited Funds Availability Act, with a compliance date of July 1, 2020. Will these changes require us to notify members?
A. Yes. While the Truth in Savings Act and its implementing regulations generally only require advance notices when members are negatively impacted, Regulation CC requires notices whenever there is a change – negative or positive – to the funds availability schedule. Specifically, §229.18(e) of Regulation CC requires credit unions to provide notice to members at least 30 days before implementing a change to its availability policy except that a change that expedites the availability of funds may be disclosed not later than 30 days after implementation.
National Credit Union Administration (NCUA)
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Internal Revenue Service (IRS)
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Federal Reserve Board (FRB)
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Office of Foreign Assets Control (OFAC)
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Questions? Contact the Compliance Hotline: 1.800.546.4465; [email protected].