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Monday, June 20, 2016

CFPB Updates Reg Z Dollar Thresholds

The CFPB has announced 2017 changes in dollar thresholds for several Regulation Z provisions governed by the CARD Act, the Home Ownership and Equity Protection Act and the Dodd-Frank Act. The thresholds are based on changes in the Consumer Price Index.

For credit cards, the penalty fees safe harbor for 2017 will remain at $27 for a first late payment. Due to a miscalculation from the previous adjustment, the bureau has recalculated the subsequent late payment safe harbor fee to be $38, effective immediately. This new figure will remain unchanged in 2017. The minimum interest charge disclosure threshold will also remain unchanged for 2017. The HOEPA loan threshold will increase slightly to $20,579 and the HOEPA fee trigger will be $1,029, effective Jan. 1.

For Qualified Mortgages, points and fees cannot exceed 3% of loans of $102,894 or more; $3,087 for loans between $61,737 and $102,894; 5% for loans between $12,862 and $20,579; and 8% for loans of less than $12,862.

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