Federal Register Publishes CFPB Notice to Renew the Approval for the Existing Collection, “Consumer Leasing Act (Regulation M)”

On May 4, the Federal Register published the CFPB’s notice and request for comment, “Consumer Leasing Act (Regulation M) 12 CFR 1013.” The CFPB is requesting to renew the approval of Regulation M without change. Consumers depend on Regulation M to shop for and compare leases, and, under Regulation M’s recordkeeping requirement, federal and state enforcement agencies are able to determine whether consumers receive accurate and complete disclosures of loan costs. Comments regarding the renewal of Regulation M are due on or before July 6, 2015.

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Federal Reserve, CFPB Announce Increased Consumer Credit, Lease Transaction Thresholds

On November 20, the Federal Reserve Board and the CFPB announced an increase in the dollar thresholds in Regulation Z (TILA) and Regulation M (Consumer Leasing) for exempt consumer credit and lease transactions. Transactions at or below the thresholds are subject to the protections of the regulations. Based on the annual percentage increase in the Consumer Price Index for Urban Wage Earners and Clerical Workers as of June 1, 2013, TILA and Consumer Leasing Act generally will apply to consumer credit transactions and consumer leases of $53,500 or less beginning January 1, 2014. Private education loans and loans secured by real property remain subject to TILA regardless of the amount of the loan.

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CFPB and Federal Reserve Board Increase Thresholds for Exempt Consumer Credit and Lease Transactions

On November 20, the CFPB and the Federal Reserve Board announced that, effective January 1, 2013, dollar thresholds in Regulation Z (TILA) and Regulation M (Consumer Leasing Act) for exempt consumer credit and lease transactions will increase to reflect the annual percentage increase in the consumer price index as of June 1, 2012. Transactions at or below the thresholds are subject to the protections of the regulations. Based on the adjustments, the TILA and Consumer Leasing Act protections generally will apply to consumer credit transactions and consumer leases of $53,000 or less in 2013. Mortgage transactions and private student loans remain subject to TILA regardless of the amount of the loan. While the CFPB has rulemaking authority under TILA and the Consumer Leasing Act, the Federal Reserve Board retains authority to issue rules for certain motor vehicle dealers. In addition to the joint adjustment, the CFPB separately adjusted the dollar amount that triggers additional protections for certain home mortgages under the Home Ownership and Equity Protection Act (HOEPA). Consistent with the increase in the consumer price index, the 2013 dollar amount of the HOEPA fee trigger will be $625.

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