OCC BULLETIN 2013-4
Subject: Truth in Lending Act
Date: February 6, 2013
To: Chief Executive Officers and Compliance Officers of All National Banks and Federal Savings Associations, Department and Division Heads, All Examining Personnel, and Other Interested Parties
Description: Annual Dollar Trigger for Certain Home Mortgages
The Consumer Financial Protection Bureau published in the November 21, 2012, Federal Register the annual amendment to its Regulation Z Commentary related to the dollar amount that triggers requirements for certain home mortgage loans subject to 12 CFR 1026.32 (formerly 12 CFR 226.32). The Home Ownership and Equity Protection Act of 1994 established rules for home-secured loans in which the total points and fees payable by the consumer at or before loan closing exceed the greater of $400 or 8 percent of the total loan amount. The dollar amount is adjusted annually based on the percentage change in the consumer price index that becomes effective June 1.
Effective January 1, 2013, the points and fees trigger is the greater of $625 or 8 percent of the total loan amount. You can find this change in the Regulation Z Official Staff Interpretations at 12 CFR 1026, Supplement I, comment 32(a)(1)(ii)–2, which lists the annual adjustments.
For further information, please contact your OCC supervisory office or the OCC Compliance Policy Department at (202) 649-5470.
Grovetta N. Gardineer