Truth in Lending (Regulation Z) Annual Threshold Adjustments (Credit Cards, HOEPA, and Qualified Mortgages)

On September 21, 2023, the Bureau of Consumer Financial Protection announced in the Federal Register upcoming changes of certain thresholds under Regulation Z (12 CFR Part 1026) which implements the Truth in Lending Act, to adjust these thresholds according to changes in the Consumer Price Index (CPI). Specifically, the Bureau announced the following:
(1) For 2024, there will be no adjustment of the threshold that „triggers requirements to disclose minimum interest changes“ for open-end credit lines;
(2) For Home Ownership and Equity Protection Act (HOEPA) loans, an adjustment will be made to the total loan amount threshold for high-cost mortgages; the new level will be set at $26,092. The adjusted points and fees dollar trigger is also increasing to $1,305; and
(3) The thresholds to determine whether a covered transaction is a qualified mortgage (total points and fees charged) are adjusted to prescribed levels.
For further details on the thresholds, particularly those mentioned under item (3), please consult the enclosed document.