On December 15, the Board of Governors of the Federal Reserve System and the CFPB issued joint final rules amending the official interpretations to their regulations implementing the Consumer Leasing Act and the Truth in Lending Act. The amendments reflect the annual inflation adjustment required by statute and increase the exemption thresholds effective January 1, 2026.
The final rules increase the exemption threshold from $71,900 to $73,400 for calendar year 2026. The agencies made the adjustment based on changes in the Consumer Price Index for Urban Wage Earners and Clerical Workers as of June 1, 2025, and the updated threshold applies beginning January 1, 2026.
The Consumer Leasing Act and the Truth in Lending Act generally exclude transactions above the applicable threshold from coverage, subject to important statutory and regulatory exceptions. Certain transactions, including credit secured by a consumer’s principal dwelling and private education loans, remain subject to Truth in Lending Act requirements regardless of loan amount. The final rules do not alter these substantive coverage rules and instead update the dollar amount used to determine whether a transaction qualifies for an exemption.
Putting It Into Practice: Federal supervision and routine regulatory implementation remain ongoing, even as parts of the federal consumer finance framework continue to shift (previously discussed here). Creditors, lessors, and service providers should confirm that transaction screening systems, policies, and compliance tools reflect the $73,400 exemption threshold beginning January 1, 2026, and ensure staff understand how threshold-based exemptions interact with transactions that remain covered regardless of dollar amount.