Clients frequently ask us about the new thresholds for various compliance rules for each year. Here’s a quick recap of some key threshold changes for 2013.
HMDA: The CFPB announced the threshold rose from $41 million in calendar year 2012 to $42 million effective January 1, 2013. This means that credit unions with assets of $42 million or less are exempt from collecting and reporting HMDA data for the 2013 calendar year.
Regulation Z and Regulation M. The Federal Reserve Board and the CFPB have announced increases in the dollar thresholds affecting certain transactions governed by Regulations M and Z. As of January 1, 2013, Regulation Z and Regulation M now applies to consumer credit transactions and consumer leases of $53,000 or less. This is an increase from the previous limit of $51,800. This limit does not apply to loans secured by real property or to private student loans. Regardless, most financial institutions provide the Reg. Z disclosures to all consumer credit and consumer lease transactions to ensure consistent procedures for all transactions of this type.
HOEPA. The dollar amount that triggers protection for certain home mortgages (High Rate, High Fee mortgages) under the Home Ownership and Equity Protection Act (HOEPA) has increased to $625 for 2013.
AffirmX clients’ CRISP manuals have been revised accordingly.
