Page 3 - September 2017

Agencies Propose Amendments to the Truth in Lending Act. CFPB is required to
Regulatory Capital Rules. calculate annually the dollar amounts for several
provisions in Regulation Z. This final rule revises, as
applicable, the dollar amounts for provisions
The Board of Governors of the Federal Reserve implementing TILA and amendments to TILA,
System (FRB), the Federal Deposit Insurance including under the Credit Card Accountability
Corporation (FDIC), and the Office of the Responsibility and Disclosure Act of 2009(CARD
Comptroller of the Currency (OCC) proposed Act), the Home Ownership and Equity Protection Act
changes to regulatory capital rules that would extend of 1994, and the Dodd-Frank Act. CFPB is adjusting
the current treatment under the capital rules for these amounts, where appropriate, based on the
certain regulatory capital deductions, risk weights, annual percentage change reflected in the Consumer
and certain minority interest requirements for Price Index in effect on June 1, 2017. For open-end
banking organizations that are not subject to the consumer credit plans under TILA, the threshold that
advanced approaches capital rules. Specifically, for triggers requirements to disclose minimum interest
non-advanced approaches banking organizations, the charges will remain unchanged at $1.00 in 2018. For
agencies propose to extend the current regulatory open-end consumer credit plans under the CARD Act
capital treatment of: mortgage servicing assets, amendments to TILA, the adjusted dollar amount for
deferred tax assets arising from temporary the safe harbor for a first violation penalty fee will
differences that could not be realized through net remain unchanged at $27 in 2018 and the adjusted
operating loss carrybacks, significant investments in dollar amount for the safe harbor for a subsequent
the capital of unconsolidated financial institutions in violation penalty fee will remain unchanged at $38 in
the form of common stock, non-significant 2018. For HOEPA loans, the adjusted total loan
investments in the capital of unconsolidated financial amount threshold for high-cost mortgages in 2018
institutions, significant investments in the capital of will be $21,032. The adjusted points and fees dollar
unconsolidated financial institutions that are not in trigger for high-cost mortgages in 2018 will be
the form of common stock, and common equity tier 1 $1,052. For the general rule to determine consumers’
minority interest, tier 1 minority interest, and total ability to repay mortgage loans, the maximum
capital minority interest exceeding the capital rules’ thresholds for total points and fees for qualified
minority interest limitations. Comments are due: mortgages in 2018 will be 3 percent of the total loan
09/25/2017. The notice may be viewed at: amount for a loan greater than or equal to $105,158;
https://www.gpo.gov/fdsys/pkg/FR-2017-08- $3,155 for a loan amount greater than or equal to
25/pdf/2017-17822.pdf. Federal Register, Vol. 82, $63,095 but less than $105,158; 5 percent of the total
No. 164, 08/25/2017, 40495-40503. loan amount for a loan greater than or equal to
$21,032 but less than $63,095; $1,052 for a loan
CFPB Finalizes Rule Adjusting Truth in amount greater than or equal to $13,145 but less than
Lending Annual Thresholds. $21,032; and 8 percent of the total loan amount for a
loan amount less than $13,145. The final rule is
The Bureau of Consumer Financial Protection effective 01/01/2018. The notice may be viewed at:
(CFPB) finalized a rule amending the official https://www.gpo.gov/fdsys/pkg/FR-2017-08-
interpretations for Regulation Z, which implements

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