The CFPB and Federal Reserve Board last week announced the dollar thresholds in Regulation Z and Regulation M that will apply for determining exempt consumer credit and lease transactions in 2020.
These thresholds are set pursuant to the Dodd-Frank Act amendments to the Truth in Lending Act and the Consumer Leasing Act, which require adjusting these thresholds annually based on the annual percentage increase in the Consumer Price Index for Urban Wage Earners and Clerical Workers. Transactions at or below the thresholds are subject to the protections of the regulations.
Based on the annual percentage increase in the CPI-W as of June 1, 2019, the protections of the Truth in Lending Act and the Consumer Leasing Act generally will apply to consumer credit transactions and consumer leases of $58,300 or less in 2020.
However, private education loans and loans secured by real property, such as mortgages, are subject to the Truth in Lending Act regardless of the amount of the loan.