Fed and CFPB set 2026 exemption thresholds for consumer credit and lease transactions
On December 15, the Fed and CFPB announced two final rules published in the Federal Register: one amending Regulation M, which implements the Consumer Leasing Act; and the second amending Regulation Z, which implements TILA, as required by the Dodd-Frank Act. Both rules set the exemption threshold for consumer credit and lease transactions at $73,400 or less for 2026, based on a 2.1 percent annual inflation increase. Under Regulation M, consumer leases with a total contractual obligation at or below the threshold are subject to disclosure requirements and other protections. Under Regulation Z, consumer credit transactions at or below the threshold are covered, while private education loans and loans secured by real property, such as mortgages, remain subject to TILA regardless of amount.