Proposed Fed Rules Expand TILA Disclosure Threshold

The Federal Reserve has issued proposed amendments to Regulation Z implementing provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act that would expand the coverage of consumer protection regulations to credit transactions and leases of higher dollar amounts.

Among other things, the proposed rules amending Regulation Z, Truth in Lending, expands TILA's credit disclosure requirements to credit transactions up to $50,000 (up from $25,000) and prohibits creditors from engaging in certain practices with respect to those loans.  Private education loans and mortgages are subject to TILA regardless of the transaction amount.  The comment period on the proposed rule expires February 1.

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