Compliance Blog

Written by Steve Van Beek

Recently, the CFPB announced the 2013 threshold levels for HOEPA/Section 32/High-Cost loans as well as exemption levels for both Reg Z and Reg M.  They haven't released the HMDA asset threshold for 2013 yet, but we'll be sure to pass that along when it is published (last year's release was, unfortunately, delayed until February 15th).  

• The HOEPA fee threshold for 2013 will be $625 in fees.  

• The Regulation M (consumer leasing) threshold for 2013 will be $53,000 (up from $51,800 in 2012).

• The Regulation Z threshold for 2013 will also be $53,000 (up from $51,800 in 2012).  

For the Reg Z threshold, a couple of things to keep in mind:

• Private student loans are subject to Reg Z regardless of the loan amount.
• Loans secured by real property (mortgages) are subject to Reg Z regardless of the loan amount.  
• Loans secured by personal property used or expected to be used as the member's principal dwelling are subject to Reg Z regardless of the loan amount.

Additionally, most credit unions provide the Reg Z disclosures for all loans (even a $55,000 closed-end car loan) in order to keep consistent for their loan teams.  

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HMDA.  Last year's asset threshold was released on February 15th even though the Federal Reserve had historically announced the updated threshold in December of the year prior.  Hopefully the CFPB has learned from its growing pains of the first year and realizes how important it is to be timely with issues as important as the annual HMDA asset threshold.