Yes, consumer loans over the threshold are exempt from many Regulation Z (Truth in Lending Act) requirements, but for 2026, that threshold is $73,400, not $71,900 (which was the 2025 limit). Loans secured by real property (mortgages) or private education loans are always covered, regardless of amount; otherwise, transactions above $73,400 (for 2026) are generally exempt from TILA's main disclosure rules.
The statement that consumer loans over $71,900 are generally exempt from Reg Z disclosure requirements is true. Under the Truth in Lending Act, also known as Regulation Z, certain consumer loans are exempted from required disclosures when the amount exceeds a specified threshold, which is currently set at $71,900.
However, several types of credit fall outside Regulation Z's scope. Business loans, commercial credit, agricultural loans, federal student loans, and loans for public utility services are generally exempt. Additionally, loans above certain dollar thresholds may be exempt from some requirements.
TILA promotes the informed use of consumer credit by requiring timely disclosure about its costs. It also includes substantive provisions such as the consumer's right of rescission on certain mortgage loans and timely resolution of billing disputes.
Effective January 1, 2026, the exemption threshold amount is increased from $71,900 to $73,400. This amount is based on the CPI-W in effect on June 1, 2025, which was reported on May 13, 2025 (based on April 2025 data).
In addition, certain types of loans are not subject to Regulation Z. These include: Federal student loans. Credit for business, commercial, agricultural or organizational use.
For 2025, $26,968, reflecting a 3.4 percent increase in the CPI-U from June 2023 to June 2024, rounded to the nearest whole dollar. xii. For 2026, $27,592, reflecting a 2.3 percent increase in the CPI-U from June 2024 to June 2025, rounded to the nearest whole dollar.
It is the purpose of the loan, not the collateral, which determines if Reg Z applies.
TILA and Regulation Z do not, however, tell financial institutions how much interest they may charge or whether they must grant a consumer a loan. The examination procedures will use “TILA” interchangeably for Truth-in-Lending Act and Regulation Z, since Regulation Z is the implementing regulation.
The Equal Credit Opportunity Act (ECOA) of 1974, which is implemented by the Board's Regulation B, applies to all creditors.
The regulation requires that the terms "finance charge" and "annual percentage rate" be disclosed more conspicuously than any other required disclosure. The finance charge and APR, more than any other disclosures, enable consumers to understand the cost of the credit and to comparison shop for credit.
Under Regulation Z, a finance charge does not include a charge imposed by a financial institution for paying items that overdraw an account unless, as is typically the case for overdraft lines of credit, the payment of such items and the imposition of the charge are previously agreed upon in writing.
Regulation Z applies to all loans secured by a residence. It does not apply to commercial loans or to agricultural loans over $25,000. Its provisions cover the disclosure of costs, the right to rescind the credit transaction, advertising credit offers, and penalties for non-compliance with the act.
Coverage Considerations under Regulation Z
(Exempt credit includes loans with a business or agricultural purpose, and certain student loans. Credit extended to acquire or improve rental property that is not owner-occupied is considered business purpose credit.)
The final rule exempted from the Regulation Z HPML escrow requirement any loan made by an insured depository institution or insured credit union and secured by a first lien on the principal dwelling of a consumer if: (1) the institution has assets of $10 billion or less; (2) the institution and its affiliates ...
Certain types of loans are not subject to Regulation Z, including federal student loans, loans for business, commercial, agricultural, or organizational use, loans above a certain amount, loans for public utility services, and securities or commodities offered by the Securities and Exchange Commission.
The exemption threshold will increase from $71,900 to $73,400 effective Jan. 1. Fair Credit Reporting Act: The CFPB issued the annual adjustment to the maximum amount consumer reporting agencies may charge consumers for making a file disclosure to a consumer under FCRA.
Regulation Z prohibits misleading terms in open-end credit advertisements. For example, an advertisement may not refer to APRs as fixed unless the advertisement also specifies a time period in which the rate will not change or that the rate will not increase while the plan is open.
The Regulation Z Total Loan Amount is calculated by the Original Loan Amount/Note Amount minus the finance charges and therefore, it should not exceed the Original Loan Amount/Note Amount.
However, private education loans and loans secured by real property, such as mortgages, are subject to Regulation Z regardless of the amount of the loan.
TILA and Regulation Z: Top 10 Material Violations
Regulation Z's Mortgage Loan Originator Rules, among other things, prohibit compensating loan originators based on a term of a mortgage transaction or a proxy for a term of a transaction, prohibit dual compensation, prohibit steering practices that do not benefit a consumer, implement licensing and qualification ...
To determine HOEPA coverage, lenders must look at three main areas:
The Bureau of Consumer Financial Protection (Bureau) issues this final rule to amend Regulation Z, which implements the Truth in Lending Act (TILA), and the official interpretations to the regulation.
TILA applies to most forms of consumer lending, including mortgages, auto loans, credit cards, and payday lending. The Consumer Financial Protection Bureau (CFPB) has rulemaking authority over TILA and its implementing regulation, Regulation Z.