Updates to TILA Interagency Guidance and Certain Annual Thresholds
Troutman Sanders
OCTOBER 28, 2021
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. For QMs under the General QM loan definition in Section 1026.43(e)(2),
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