The CFPB has announced the 2024 dollar amounts for the annual threshold adjustments for Regulation Z, Truth in Lending Act (TILA).
  • For open-end consumer credit plans under TILA, the threshold that triggers requirements to disclose minimum interest charges will remain unchanged at $1 in 2024.
  • For HOEPA loans, the adjusted total loan amount threshold for high-cost mortgages will be $26,092. The adjusted points-and-fees dollar trigger for high-cost mortgages will be $1,305.
  • For qualified mortgages (QM) under the general QM loan definition, the thresholds for the spread between the APR and the APOR in 2024 will be:
  • 2.25 or more percentage points for a first-lien covered transaction with a loan amount greater than or equal to $130,461;
  • 3.5 or more percentage points for a first-lien covered transaction with a loan amount greater than or equal to $78,277 but less than $130,461;
  • 6.5 or more percentage points for a first-lien covered transaction with a loan amount less than $78,277;
  • 6.5 or more percentage points for a first-lien covered transaction secured by a manufactured home with a loan amount less than $130,461;
  • 3.5 or more percentage points for a subordinate-lien covered transaction with a loan amount greater than or equal to $78,277; or
  • 6.5 or more percentage points for a subordinate-lien covered transaction with a loan amount less than $78,277.
  • For all categories of QMs, the thresholds for total points and fees in 2024 will be:
  • 3% of the total loan amount for a loan greater than or equal to $130,461;
  • $3,914 for a loan amount greater than or equal to $78,277 but less than $130,461;
  • 5% of the total loan amount for a loan greater than or equal to $26,092 but less than $78,277;
  • $1,305 for a loan amount greater than or equal to $16,308 but less than $26,092; and
  • 8% of the total loan amount for a loan amount less than $16,308.
You can access the final rule here.
CCI suggests sharing this information with your lending staff and the person responsible for updating loan software at your institution.  As always, CCI is available for any compliance-related questions.