Agencies Announce Dollar Thresholds for Applicability of Truth in Lending and Consumer Leasing Rules for Consumer Credit and Lease Transactions
The CFPB and FRB have announced updated dollar thresholds for Truth in Lending and Consumer Leasing rules, affecting which transactions are subject to Regulation Z and Consumer Leasing Act requirements. The thresholds are adjusted annually based on the Consumer Price Index.
Aforeworn detected this change in the Auto Dealer F&I Compliance space on July 7, 2026 and published this briefing so affected operators are forewarned rather than caught off guard. It is rated Medium urgency. All auto dealers offering consumer credit or leases, including franchise, independent, and BHPH dealers. should confirm how it applies to their specific situation before acting. There is a time constraint attached: January 1, 2025. Acting after that point can mean penalties, a lapsed licence, or lost eligibility — exactly the kind of surprise Aforeworn exists to prevent. Aforeworn monitors Auto Dealer F&I Compliance continuously and turns every detected change into a plain-English briefing like this one, so you always know first. Forewarned is forearmed.
What changed
The dollar threshold for exempt consumer credit transactions (Regulation Z) increased from $69,500 to $71,900, and the threshold for consumer leasing (Regulation M) increased from $69,500 to $71,900, effective January 1, 2025.
Who it affects
All auto dealers offering consumer credit or leases, including franchise, independent, and BHPH dealers.
What you must do
Update compliance procedures and systems to reflect the new thresholds for determining which transactions are subject to TILA and CLA disclosure requirements.
Deadline
January 1, 2025
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