Truth in Lending Act (Regulation Z) Adjustment to Asset-Size Exemption Threshold
The CFPB adjusted the asset-size exemption threshold under Regulation Z (Truth in Lending Act) for 2026. This affects which auto dealers are exempt from certain TILA requirements, such as disclosure rules for financing and add-on products.
Aforeworn detected this change in the Auto Dealer F&I Compliance space on July 14, 2026 and published this briefing so affected operators are forewarned rather than caught off guard. It is rated Medium urgency. Franchise dealers, independent used-car dealers, BHPH dealers, and F&I managers whose assets are near the new threshold. should confirm how it applies to their specific situation before acting. There is a time constraint attached: Compliance required as of the effective date of the rule (likely 30 days after publication in Federal Register, or as specified). Check the exact effective date in the final rule.. 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 asset-size exemption threshold for creditors under Regulation Z has been updated for 2026. Dealers with assets below the new threshold may be exempt from certain TILA requirements; those above must comply.
Who it affects
Franchise dealers, independent used-car dealers, BHPH dealers, and F&I managers whose assets are near the new threshold.
What you must do
Determine if your dealership's assets exceed the new threshold. If so, ensure all financing disclosures (including for add-on products like GAP waivers) comply with TILA/Regulation Z. If below, verify continued exemption eligibility.
Deadline
Compliance required as of the effective date of the rule (likely 30 days after publication in Federal Register, or as specified). Check the exact effective date in the final rule.
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