The Consumer Financial Protection Bureau (CFPB) has announced the threshold amounts under Regulation Z, which implements the Truth in Lending Act (TILA), for 2018 based on the annual percentage change reflected in the Consumer Price Index in effect on June 1, 2017.

This final rule is effective January 1, 2018.

 

Open-End Consumer Credit Plans

The threshold that triggers requirements to disclose minimum interest charges on open-end consumer credit plans will remain unchanged at $1.00 in 2018.

Credit Cards

The first penalty fee for violating the terms of a credit card agreement under the CARD Act will remain unchanged at $27 in 2018, and the adjusted dollar amount for the safe harbor for a subsequent violation penalty fee will remain unchanged at $38.

High-Cost Mortgages

For high-cost mortgages, the adjusted total loan amount threshold in 2018 will be $21,032. The adjusted points and fees dollar trigger for high-cost mortgages in 2018 will be $1,052.

When the total loan amount for a transaction is $21,032 or more, and the points and fees amount exceeds 5% of the total loan amount, the transaction is a high-cost mortgage. When the total loan amount for a transaction is less than $21,032, and the points and fees amount exceeds the lesser of the adjusted points and fees dollar trigger of $1,052 or 8% of the total loan amount, the transaction is a high-cost mortgage.

Qualified Mortgage Loans

In 2018 a covered transaction will not be considered a qualified mortgage if the maximum thresholds for total points and fees for qualified mortgages below exceed:

  • 3% of the total loan amount for a loan greater than or equal to $105,158;
  • $3,155 for a loan amount greater than or equal to $63,095 but less than $105,158;
  • 5% of the total loan amount for a loan greater than or equal to $21,032 but less than $63,095;
  • $1,052 for a loan amount greater than or equal to $13,145 but less than $21,032; and
  • 8% of the total loan amount for a loan amount less than $13,145.