The Jan. 1, 2019, thresholds, revised where necessary based on review of the consumer price index (CPI), are detailed in a notice slated for publication Monday in the Federal Register. Here they are:
Open-end consumer credit plans under TILA
The threshold that triggers requirements to disclose minimum interest charges will remain unchanged at $1.
Open-end consumer credit plans under the CARD Act
The adjusted dollar amount for the safe harbor for a first violation penalty fee will increase by $1 to $28; the adjusted dollar amount for the safe harbor for a subsequent violation penalty fee will increase by $1 to $39.
HOEPA loans
The adjusted total loan amount threshold for high-cost mortgages will be $21,549. The adjusted points-and-fees dollar trigger for high-cost mortgages will be $1,077.
Qualified mortgages
These loans receive certain protections from liability under the TILA ability-to-repay rule. Maximum thresholds for total points and fees in 2019 are revised to:
- 3% of the total loan amount for a loan greater than or equal to $107,747;
- $3,232 for a loan amount greater than or equal to $64,648 but less than $107,747;
- 5% of the total loan amount for a loan greater than or equal to $21,549 but less than $64,648;
- $1,077 for a loan amount greater than or equal to $13,468 but less than $21,549; and
- 8% of the total loan amount for a loan amount less than $13,468.
Truth in Lending (Regulation Z) Annual Threshold Adjustments (Credit Cards, HOEPA, and Qualified Mortgages) – Effective Jan. 1, 2019