In a September 9, 2014 notice, the Board of Governors of the Federal Reserve System (FRB) and the Consumer Financial Protection Bureau (CFPB) published final rules amending the official interpretation and commentary to Regulations Z by increasing the threshold for exempt consumer credit transactions to $54,600, effective January 1, 2015. Recall that effective July 21, 2011, the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) amended the Truth in Lending Act by increasing the threshold for exempt consumer credit transactions from $25,000 to $50,000 and requiring that, on or after December 31, 2011, this threshold be adjusted annually. See this firm’s April 5, 2011 memorandum discussing this Dodd-Frank Act amendment, which is posted on our web site at www.bmandg.com. Accordingly, the FRB and the CFPB are adjusting the exemption threshold to $54,600, effective January 1, 2015. You are advised that the threshold amount for exempt consumer credit transactions does not apply to the following consumer credit transactions: (1) a consumer credit transaction secured by (i) any real property, or (ii) personal property that is used or expected to be used as the consumer’s principal dwelling; and, (2) a private education loan. These loans remain subject to Regulation Z regardless of the amount of credit extended or to be extended under these loans. The notice will be published shortly in the Federal Register.
