On October 25, the CFPB has issued its annual Regulation Z threshold adjustments. This final rule adjusts the dollar amounts for Regulation Z (TILA), including the Credit Card Accountability Responsibility and Disclosure Act (CARD Act), the Home Ownership and Equity Protection Act (HOEPA), and the Dodd-Frank Act. These Regulation Z threshold adjustments are effective January 1, 2022.
Minimum interest charges for disclosure on open-end consumer credit plans: unchanged at $1.
Credit card late fee caps are increased:
- First late fee: $30.
- Subsequent late fee: $41.
For HOEPA loans, thresholds for high-cost mortgages are:
- Total loan amount will be $22,969.
- Points and-fees trigger will be $1,148.
First-lien transactions that meet the General QM definition can not have an APR/APOR spread exceeding:
- 25 percentage points on loans greater than or equal to $114,847;
- 5 on loans greater than or equal to $68,908 but less than $114,847;
- 5 on loans less than $68,908; and
- 5 on manufactured home loans less than $114,847.
For subordinate liens transactions that meet the General QM definition can not have an APR/APOR spread exceeding:
- 5 percentage points on loans greater than or equal to $68,908; and
- 5 on loans less than $68,908.
For all categories of QMs, the thresholds for total points and fees will be:
- 3 percent of the total loan amount for a loan greater than or equal to $114,847;
- $3,445 ($3,000 in 2021) for a loan amount greater than or equal to $68,908 but less than $114,847;
- 5 percent of the total loan amount for a loan greater than or equal to $22,969 but less than $68,908;
- $1,148 ($1,000 in 2021) for a loan amount greater than or equal to $14,356 but less than $22,969;
- and 8 percent of the total loan amount for a loan amount less than $14,356.
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