CFPB annual CARD Act, HOEPA, QM adjustments do not include credit card penalty fees safe harbors (UPDATED)

The CFPB recently posted on its website a final rule regarding various annual adjustments it is required to make under provisions of Regulation Z (TILA) that implement the CARD Act, HOEPA, and the ability to repay/qualified mortgage provisions of Dodd-Frank. The adjustments reflect changes in the Consumer Price Index (CPI) in effect on June 1, 2023 and will take effect January 1, 2024. The adjustments do not include adjustments to the credit card penalty fees safe harbor....
By: Ballard Spahr LLP