U.S. Federal Reserve expands consumer protection regulations for credit transactions and leases of higher dollar amounts
Mar 25, 2011
On March 25, 2011, the Federal Reserve Board adopted two rules that would expand the coverage of consumer protection regulations to credit transactions and leases of higher dollar amounts.
The final rules amend Regulation Z (Truth in Lending) and Regulation M (Consumer Leasing) to implement a provision of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Effective July 21, 2011, the Dodd-Frank Act requires that the protections of the Truth in Lending Act (“TILA”) and the Consumer Leasing Act (“CLA”) apply to consumer credit transactions and consumer leases up to $50,000, compared with $25,000 currently. This amount will be adjusted annually to reflect any increase in the consumer price index.
TILA requires creditors to disclose key terms of consumer loans and prohibits creditors from engaging in certain practices with respect to those loans. Currently, consumer loans of more than $25,000 are generally exempt from TILA. However, private education loans and loans secured by real property (such as mortgages) are subject to TILA regardless of the amount of the loan.
The CLA requires lessors to provide consumers with disclosures regarding the cost and other terms of personal property leases. An automobile lease is the most common type of consumer lease covered by the CLA. Currently, a lease is exempt from the CLA if the consumer’s total obligation exceeds $25,000.
The notices that will be published in the Federal Register are attached.
2011 Banking and Consumer Regulatory Policy