Attention all NYAMB Members

In an effort to keep you informed of recent regulatory updates that may impact you, we are forwarding the following information sent out by the CFPB today.

Date: October 15, 2024

Subject: CFPB has announced three rulemakings related to threshold adjustments

The first rule is a joint rulemaking between the CFPB, the Federal Reserve Board, and the Office of the Comptroller of the Currency to adjust the threshold for exempting loans from special appraisal requirements under the TILA Higher Priced Mortgage Loan Appraisal rule. This adjustment is effective January 1, 2025.

The second and third rules are joint rulemakings between the CFPB and the Federal Reserve Board to adjust the thresholds in Regulation Z and Regulation M for determining the exempt consumer credit transactions under TILA and the exempt consumer lease transactions under the Consumer Leasing Act. These adjustments are effective January 1, 2025.

You can read more about the HPML threshold adjustment here: https://www.consumerfinance.gov/policy-compliance/rulemaking/final-rules/appraisals-higher-priced-mortgage-loans-exemption-threshold-adjustments/.

You can read more about the Regulation Z threshold adjustment here: https://www.consumerfinance.gov/policy-compliance/rulemaking/final-rules/truth-lending-regulation-z-threshold-adjustments/.

You can read more about the Regulation M threshold adjustment here: https://www.consumerfinance.gov/policy-compliance/rulemaking/final-rules/consumer-leasing-regulation-m-adjustments/.

Thank you

Consumer Financial Protection Bureau 

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Sincerely,

Mark Favaloro

Chairman of the Board, Legislative Committee Co-Chair

New York Association of Mortgage Brokers