Removing Barriers Blog

BCFP Issues TILA Threshold Adjustments
Posted August 24, 2018 by CUNA Advocacy

Today, the BCFP issued its annual threshold adjustments for regulations implementing TILA and amendments to TILA, including 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 Act.  These thresholds are adjusted annually based on changes in the Consumer Price Index. 

Of note, after being unchanged in 2018, the CARD Act penalty fee safe harbor is being increased by $1 for 2019. As a result, the penalty fee safe harbor for violating the terms of an open-end consumer credit plan will be $28 for a first violation and $39 for a subsequent violation.

Threshold changes were also made for HOEPA loans and provisions relating to qualified mortgages.  All adjustments will be published to the federal register on Monday, August 24 and are effective on January 1, 2019.