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OCC BULLETIN 2011-36
Subject: Truth in Lending Act
Date: September 7, 2011
To: Chief Executive Officers and Compliance Officers of All National Banks and Federal Savings Associations, Department and Division Heads, and All Examining Personnel
Description: Annual Dollar Trigger for Certain Home Mortgage Loans
The Board of Governors of the Federal Reserve System published in the June 20, 2011, Federal Register its annual amendment to its Regulation Z Commentary related to the dollar amount that triggers requirements for certain home mortgage loans subject to 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 on June 1.
Effective January 1, 2012, the points and fees trigger is the greater of $611 or 8 percent of the total loan amount. You can find this change in the Regulation Z Official Staff Interpretations at 12 CFR 226.32(a)(1)(ii), Supplement I, comment 32(a)(1)(ii)-2, which lists the annual adjustments.
For further information, please contact your Examiner-in-Charge, your OCC supervisory office, or the OCC Compliance Policy Department at (202) 649-5470.
Grovetta N. Gardineer