In my last blog post, I opened with my plans to plan for next year. I have to admit, I still have not gotten around to it, and I feel like time is just slipping through my fingers! I can see my new planner in my bookshelf, taunting me – no, daring me – to start filling its pages with deadlines and fun plans to look forward to. Thankfully, not everyone is as behind as me. Each year, the Consumer Financial Protection Bureau (CFPB) provides annual adjustments to certain dollar amount thresholds covered in Regulation Z. This year has been speeding by, but we didn’t want to say “Happy New Year” without providing an update! As the holiday season can provide a bit of a slowdown during the workday, this may be a good time to review any internal procedures and documents to ensure these thresholds are up-to-date when everyone clocks in on January 3rd.
The adjustments can be found in the final rule and at the CFPB’s webpage for Truth in Lending (Regulation Z) Annual Threshold Adjustments (Credit Cards, HOEPA, and Qualified Mortgages), and are effective as of January 1, 2022.
Section 1026.52(b)(1)(ii) provides that a credit union “may impose a fee for violating the terms or other requirements of an account if the dollar amount does not exceed” the safe harbor amounts. For 2022, the penalty fee safe harbor amounts have both been increased:
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