Regulators Raise Exemption Thresholds Regarding Mortgages, Consumer Credit and Leases

The Consumer Financial Protection Bureau (CFPB) has announced rules related to threshold adjustments for mortgage loan appraisals, consumer credit transactions and consumer lease transactions.

All three threshold adjustments will increase, effective Jan. 1, 2025.

The exemption threshold for special appraisal requirements for “higher-priced mortgage loans” or HPMLs under Section 129H of the Truth in Lending Act (TILA) will increase from $32,400 to $33,500, the CFPB said in a Tuesday (Oct. 15) press release.

That adjustment results from a joint rulemaking made by the CFPB, the Federal Reserve Board and the Office of the Comptroller of the Currency (OCC), according to the release.

The exemption threshold for consumer credit transactions under the TILA, as amended by the Dodd-Frank Act, will increase from $69,500 to $71,900, according to another Tuesday press release.

This adjustment comes from a joint rulemaking between the CFPB and the Federal Reserve Board, the release said.

The exemption threshold for consumer leasing under the Consumer Leasing Act (CLA), as amended by the Dodd-Frank Act, will increase from $69,500 to $71,900, according to a third Tuesday press release.

This adjustment comes from another joint rulemaking between the CFPB and the Federal Reserve Board.

All three adjustments are based on the annual percentage increase in the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W) as of June 1, 2024, per the release.

In another, separate action, the CFPB said Thursday (Oct. 10) that it has barred dispute resolution platform Ejudicate from arbitrating disputes about consumer financial products.

The ban came after the CFPB found that the company had misled student loan borrowers about its neutrality and undertook “sham” arbitration proceedings.

“Arbitration outfits cannot rig the process against consumers to enrich their corporate clients,” CFPB Director Rohit Chopra said in a press release announcing the decision.

On Oct. 7, the CFPB said it is taking action against improper automobile repossessions after finding cases of lenders repossessing cars after borrowers have made payments or gotten extensions on their loans; subprime lenders charging customers for optional add-on products that the buyers didn’t purchase; and loan servicers misallocating borrowers’ auto loan payments.