Fed Proposes Rules to Expand Applicability of Regs Z and M to Transactions Up to $50,000

At present, Regs Z and M apply only to transactions of up to $25,000 (except that Reg Z also applies to mortgages, of course).  That means consumers taking out large car loans or entering into expensive car leases, say, aren't required to receive the Truth in Lending or the Consumer Leasing Act disclosures (though some states have required as a matter of state law that the disclosures be given in larger transactions).  Dodd-Frank increased the coverage of the laws to transactions of up to $50,000, effective next July. The Fed has now proposed regulations to implement that change.  

Comments

[Jeremy]

Credit transactions over $50,000 and leases for which the consumer’s total obligation exceeds $50,000 will continue to be exempt from the TILA and CLA protections on the theory that those who undertake such relatively high-value transactions are more sophisticated and do not need the disclosures and other protections that apply to retail consumers who undertake smaller-value credit and lease transactions.
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