Q: Credit union writes that, “You mentioned an exclusion for coverage of credit in excess of the $54,600 threshold. Please explain the $54,600 threshold.”
A: Under TILA, most non-mortgage consumer transactions for more than $50,000 are excluded from TILA and Regulation Z coverage. TILA requires the Consumer Financial Protection Bureau to adjust that threshold figure annually according to changes in the consumer price index.
The 2016 threshold is $54,600. Because the amended regulation excludes from MLA coverage most credit exempt from TILA coverage, the $54,600 cap also applies to the MLA. An exception to that rule is private student loans. They are covered by TILA and the MLA even if they exceed the $54,600 threshold.