David Mulkerin

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HPML Appraisal & Regulation Z and Regulation M Exemption Dollar Thresholds for 2025

On October 4, 2024, the Federal Reserve Board and the Consumer Financial Protection Bureau jointly issued an increase in the exemption thresholds for Regulation Z and Regulation M exemptions, which are tied to the Consumer Price Index (CPI-W) as of June 1. Loans or leases at or below the thresholds are subject to the protections

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CFPB Funding Mechanism Determined Valid

The Supreme Court released their decision in the Consumer Financial Protection Bureau v. Community Financial Services Assn. of America, Ltd. case, which was brought to challenge the funding of the CFPB as inconsistent with the Appropriations Clause. The challengers argued that this funding mechanism violated the appropriations clause, which provides that “no money shall be

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