The CFPB recently issued a final rule adjusting the Truth in Lending Act (TILA) dollar amounts for certain provisions. The CFPB is adjusting these amounts, where appropriate, based on the annual percentage change reflected in the Consumer Price Index (CPI) in effect on June 1, 2023. Specifically, the final rule provides for the following adjustments:
- For open-end consumer credit plans under TILA, the threshold that triggers requirements to disclose minimum interest charges will remain unchanged at $1.00 in 2024.
- For HOEPA loans, the adjusted total loan amount threshold for high-cost mortgages in 2024 will be $26,092, and the adjusted points and fees dollar trigger for high-cost mortgages in 2024 will be $1,305.
- For qualified mortgages (QMs) under the General QM loan definition in § 1026.43(e)(2), the thresholds for the spread between the annual percentage rate (APR) and the average prime offer rate (APOR) in 2024 will be:
- 2.25 or more percentage points for a first-lien covered transaction with a loan amount greater than or equal to $130,461;
- 3.5 or more percentage points for a first-lien covered transaction with a loan amount greater than or equal to $78,277 but less than $130,461;
- 6.5 or more percentage points for a first-lien covered transaction with a loan amount less than $78,277;
- 6.5 or more percentage points for a first-lien covered transaction secured by a manufactured home with a loan amount less than $130,461;
- 3.5 or more percentage points for a subordinate-lien covered transaction with a loan amount greater than or equal to $78,277; or
- 6.5 or more percentage points for a subordinate-lien covered transaction with a loan amount less than $78,277.
- For all categories of QMs, the thresholds for total points and fees in 2024 will be:
- 3 percent of the total loan amount for a loan greater than or equal to $130,461;
- $3,914 for a loan amount greater than or equal to $78,277 but less than $130,461;
- 5 percent of the total loan amount for a loan greater than or equal to $26,092 but less than $78,277;
- $1,305 for a loan amount greater than or equal to $16,308 but less than $26,092; and
8 percent of the total loan amount for a loan amount less than $16,308.
These adjustments are effective January 1, 2024.
For further information about items in this L & T Bulletin, please contact ICUL’s Compliance & Advocacy Office:
| Joni Senkpeil | [email protected] | 630-983-2723 |
| Kari Osier | [email protected] | 630-983-3412 |
| Shannon Basile | [email protected] | 630-983-3407 |
| Ashley Sharp | [email protected] | 217-744-1803 |
| Patrick Smith | [email protected] | 217-744-1802 |
| Stephen R Olson | [email protected] | 630-712-9378 |