CFPB, Fed set thresholds for consumer credit, lease transactions

The dollar thresholds that will apply for determining exempt consumer credit and lease transactions in 2019 have been set by the Federal Reserve Board and the Consumer Financial Protection Bureau (CFPB).

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These thresholds are set under amendments to the Truth in Lending Act and the Consumer Leasing Act that were part of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Dodd-Frank requires adjusting these thresholds annually based on the annual percentage increase in the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W).

Based on the annual percentage increase in the CPI-W as of June 1, 2018, the protections of the Truth in Lending Act and the Consumer Leasing Act will apply to consumer credit transactions and consumer leases of $57,200 or less in 2019. Private education loans and loans secured by real property, such as mortgages, are subject to the Truth in Lending Act.

If there is no annual percentage increase in the CPI-W, these exemption thresholds will not be adjusted. If there is no annual percentage increase in the CPI-W, these exemption thresholds will not be adjusted. In the years following a year in which the exemption threshold was not adjusted, the threshold is calculated by applying the annual percentage change in CPI-W to the dollar amount that would have resulted. Transactions at or below the thresholds are subject to the protections of the regulations.