On October 4, the
CFPB and the
Fed announced adjusted dollar thresholds for 2025 that determine whether certain consumer credit and lease transactions are subject to protections under
TILA Regulation Z and
Consumer Leasing Regulation M. These thresholds are adjusted annually based on the annual percentage increase in the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W), as required by law. For 2025, the thresholds have been set at $71,900 or less, reflecting a 3.4 percent increase in the CPI-W as of June 1. Generally, consumer credit transactions and consumer leases at or below this amount will be subject to the regulations’ protections, though private education loans and loans secured by real property are subject to Regulation Z regardless of the loan amount.
On the same day, the CFPB, Fed and OCC also released thresholds for higher-priced mortgage loans subject to special appraisal requirements. The threshold will increase from $32,400 to $33,500, effective January 1, 2025. The adjustment is also based on a 3.4 percent increase in the CPI-W as of June 1. The agencies noted that, pursuant to Dodd-Frank, special appraisal requirements were added to TILA for higher-priced mortgage loans, mandating that creditors obtain a written appraisal, which includes a physical inspection of the home’s interior, before issuing a higher-priced mortgage loan.
