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Updates to TILA Interagency Guidance and Certain Annual Thresholds

Troutman Sanders

Specifically, the final rule provides for the following adjustments: For open-end consumer credit plans under TILA, the threshold that triggers requirements to disclose minimum interest charges will remain unchanged at $1.00 The rule takes effect on January 1, 2022. 8% of the total loan amount for a loan amount less than $14,356.

Loans 52
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Troutman Pepper Weekly Consumer Financial Services Newsletter

Troutman Sanders

On June 8, the board of governors for the Federal Reserve (the Fed), Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), National Credit Union Administration (NCUA), and the OCC requested public comment on proposed guidance addressing reconsiderations of value (ROV) for residential real estate transactions.

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Troutman Pepper Weekly Consumer Financial Services Newsletter

Troutman Sanders

The bulletin also discusses the “shadow financial” functions enabled by crypto markets, which share many of the vulnerabilities of traditional finance. The proposals will modify the cost and delivery of care so that no New Yorker will not “have to choose between their health and their financial security.”