Recently, the Consumer Financial Protection Bureau (“CFPB”) issued its annual adjustments to the dollar amounts of various thresholds under the Truth in Lending Act (“TILA”), effective January 1, 2017. In addition, the CFPB corrected a calculation error pertaining to the 2016 subsequent violation penalty safe harbor fee.
Specifically, the CFPB’s action adjusted the dollar amounts for several provisions in Regulation Z, which implements TILA, including under the Credit Card Accountability Responsibility and Disclosure Act of 2009 (“CARD Act”), the Home Ownership and Equity Protection Act of 1994 (“HOEPA”), and the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”).
In a separate interim final rule, the CFPB issued adjustments to the civil monetary penalties within the CFPB’s jurisdiction.
Financial institutions should review the requirements and assess necessary adjustments to their operational processes and procedures.
If you have any questions, please contact Spilman.