CFPB Releases Annual Threshold Adjustments for Regulation Z


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 3of 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; 5of 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 8of 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.

Related Links 


Legal Briefs 

National Credit Union Administration (NCUA) 

NCUA announced the release of a new digital tool to help with the chartering process. 

Internal Revenue Service (IRS) 

IRS unveiled a redesigned W-4 form for tax year 2020. 

Federal Reserve Board (FRB) 

FRB announced plans to develop a new round-the-clock real-time payment and settlement service called the FedNow Service to support faster payments in the United States. 

Office of Foreign Assets Control (OFAC) 

OFAC has updated the SDN list as of Aug. 6, 2019. The last update prior to this was Aug. 1, 2019. 

Questions? Contact the Compliance Hotline: 1.800.546.4465;

Posted in Compliance News.