CCUL Headlines: Compliance

CUNA Compliance summarizes 2018 Reg. Z thresholds

Thursday, September 7, 2017   (0 Comments)
Posted by: CUNA News
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Editor’s Note: This article was originally featured on CUNA News on Sept. 5, 2017 and has been modified.

The Consumer Financial Protection Bureau (CFPB) announced 2018 thresholds applicable under Regulation Z last week. On an annual basis, the bureau is required to adjust certain thresholds under Regulation Z.

These changes will be effective Jan. 1, 2018.

Requirements for High-Cost Mortgages

A loan can be classified as a high-cost mortgage based on 1 of 3 independent triggers, including the points and fees charged in connection with the transaction.

Starting Jan. 1, a loan will be classified as high-cost if the total points and fees charged in connection with the transaction exceed:

  • 5% of the loan amount for loans greater than $21,032; or
  • For loans of less than $21,032, the lesser of 8% of the loan amount or $1,052


Limitations on credit card fees

Regulation Z establishes a safe harbor for the imposition of penalty fees in association with credit card accounts. A credit union is considered to be compliant as long as their penalty fees do not exceed the following amounts:

  • $27 for a first violation; and
  • $38 for a subsequent violation

These thresholds remain unchanged from the current 2017 levels.


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