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Updates to TILA Interagency Guidance and Certain Annual Thresholds

Troutman Sanders

The rules in question were issued by the Consumer Financial Protection Bureau (CFPB) in 2020 and 2021. The updates reflect changes to the definition of a General QM loan and the addition of a new category of QM, Seasoned QM loans. For QMs under the General QM loan definition in Section 1026.43(e)(2),

Loans 52
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CFPB Announces Annual Threshold Adjustments for Credit Cards and Mortgages

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 For qualified mortgages (QMs) under the General QM loan definition in §1026.43(e)(2),

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Troutman Pepper Weekly Consumer Financial Services Newsletter

Troutman Sanders

On November 9, the Department of Education (DOE) announced its plan to implement an oversight strategy of federal student loan servicers that provides several pathways for identifying problems that can harm borrowers, in real-time. For more information, click here. For more information, click here. For more information, click here.

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Troutman Pepper Weekly Consumer Financial Services Newsletter

Troutman Sanders

On October 21, the Eighth Circuit temporarily blocked President Joe Biden’s student loan forgiveness program. On October 20, Supreme Court Justice Amy Coney Barrett, who oversees Seventh Circuit emergency matters, rejected an emergency request to stop President Biden’s student loan forgiveness program. For more information, click here.