Yes, for 2025, consumer loans (non-mortgage/non-HELOC) over $71,900 are generally exempt from Regulation Z Truth in Lending Act (TILA) disclosure requirements. This threshold increases annually based on the CPI-W; effective January 1, 2026, the exemption threshold rises to $73,400. Loans secured by real property or a principal dwelling remain covered regardless of amount.
Annual threshold adjustments. Based on the CPI-W in effect as of June 1, 2025, the exemption threshold will increase from $71,900 to $73,400, effective Jan. 1, 2026.
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.)
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.
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.
The right of rescission applies only to certain types of home loans, including:
What Loan Types Are Exempt From the Ability to Repay Requirements? Several loans don't have to meet ATR requirements. These include home equity lines of credit (HELOC), reverse mortgages, bridge loans with 12-month terms or less, and construction loans.
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 ...
Truth in Lending Act (Regulation Z)
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.
Debt that are not regulated include:
Mortgages. Debts to family or friends. Debts to unlicensed lenders or loan sharks. Household bills like gas, electricity and water.
Special disclosures are required of certain products, such as reverse mortgages, certain variable-rate loans, and certain mortgages with rates and fees above specified thresholds. TILA and Regulation Z also contain rules concerning credit advertising.
The Equal Credit Opportunity Act (ECOA) of 1974, which is implemented by the Board's Regulation B, applies to all creditors.
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.
While all types of consumer credit are covered by the MLA such as credit cards, payday alternative loans, and overdraft lines of credit – any credit that is secured by property that was purchased with the credit is NOT covered by the MLA, so excluded from the MLA would be credit like mortgage loans and auto loans.
12 CFR Part 1026 - Truth in Lending (Regulation Z)
Business loans, personal guarantees, tax debt, mortgages for business properties, and necessary medical bills and legal fees are all categorized as non-consumer debt. All of this is either accrued for business purposes or otherwise unrelated to the debtor's consumption.
Transactions Exempt from the Preview of TILA
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.
The following transactions are not required to be reported under Regulation C:
The Basics of Consumer Loans. There are two primary types of debt: secured and unsecured. Your loan is secured when you put up security or collateral to guarantee it. The lender can sell the collateral if you fail to repay.
The answer is that loans where already-owned homes are used as collateral (like refinancing loans and home equity loans) are eligible for a three-day right of rescission under Regulation Z.