Agencies set 2022 exemption thresholds for consumer leases, consumer credit, appraisals of higher-priced mortgages

Amounts above, or below, which certain federal disclosure, interest rate, fee, and other requirements and limitations apply for consumer leases, consumer credit, and higher-priced mortgage loans (HPMLs) are revised up nearly 5% for 2022 under the Truth in Lending Act (TILA) and Consumer Leasing Act (CLA), according to notices published Tuesday in the Federal Register.

The revisions for HPMLs were made jointly by the Consumer Financial Protection Bureau (CFPB), Federal Reserve, and Office of the Comptroller of the Currency (OCC). The revisions affecting consumer leases and consumer credit were published by the CFPB and the Fed.

These changes, according to Tuesday’s notices, go into effect Jan. 1, 2022:

  • HPMLs: The exemption threshold is $28,500, up $1,300 (4.8%) from the $27,200 threshold in effect this year. Under Regulation Z (implementing TILA), appraisals are not required for loans equal to or below the exemption threshold dollar amount.
  • Consumer leases, consumer credit: The exemption threshold is $61,000, up $2,700 (4.6%) from this year’s threshold of $58,300. Under Regulation M (CLA) and Regulation Z, requirements for certain disclosures, fee and interest rate limits, and more do not apply when the credit extended exceeds the exemption threshold dollar amount.

The revisions, reflected in the agencies’ rules and official interpretations and commentary, are based on the annual percentage increase in the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W) as of June 1, according to the notices.

TILA HPML appraisal exemption threshold

CLA exemption threshold

TILA consumer credit exemption threshold