CFPB Final Rules

Key dates

2026-06-25

The joint final rule was issued and published in the Federal Register as 91 FR 38246.

2026-10-01

The joint final rule becomes effective. Its standards become available for consideration in later agency-specific reporting requirements, but existing reporting requirements do not change solely because of this effective date.

Suggested considerations

• Compliance teams may wish to inventory all regulatory data collections submitted to the CFPB, SEC, CFTC, Federal Reserve, OCC, FDIC, NCUA, FHFA, or Treasury and identify the systems, vendors, data owners, and filing processes supporting each collection.
• Firms should consider assessing whether legal entities in their reporting perimeter already have active ISO 17442 LEIs, while recognizing that the joint rule does not presently impose an LEI-obtaining or renewal requirement.
• Data-governance teams may wish to map current entity, product, instrument, location, date, and currency fields to the joint standards and document data lineage, semantic definitions, validation controls, and taxonomy dependencies.
• Technology and regulatory-reporting teams should consider evaluating whether reporting platforms can produce machine-readable data and accommodate future agency-specific identifier, schema, taxonomy, or transmission requirements without duplicative migrations.
• Firms with SEC or MSRB reporting exposure may wish to monitor the SEC's agency-specific implementation and assess the potential effect on municipal securities data, including whether CUSIP remains acceptable.
• Compliance teams may wish to monitor each covered agency's rulemakings and other implementation actions rather than treating October 1, 2026 as a deadline to change all existing regulatory filings.

What changed

The final rule establishes common identifiers and technical conventions for certain regulatory data collections, including ISO 17442 as the common Legal Entity Identifier standard, identifiers for products or financial instruments, dates, geographic locations, states, countries, and currencies. It also establishes a principles-based standard for data transmission and schema and taxonomy formats, requiring data to be machine-readable, semantically defined, consistently identified in accordance with the applicable regulatory requirement, and based on nonproprietary or openly licensed standards...

Key dates

2025-12-15

The CFPB and Federal Reserve announced and issued the final threshold amendments based on the 2.1% CPI-W increase as of June 1, 2025.

2026-01-01

The $73,400 Regulation Z and Regulation M thresholds became effective.

2026-12-31

The stated $73,400 thresholds apply through the end of the 2026 calendar year, subject to the applicable transaction-date rules.

Suggested considerations

• Compliance teams may wish to update underwriting, product-classification, and regulatory-coverage logic so that transactions of $73,400 or less are treated as within the applicable Regulation Z or Regulation M framework for the relevant 2026 transaction date.
• Firms should consider reviewing transaction-value calculations, including the total contractual obligation for consumer leases, to confirm that threshold determinations are made using the applicable regulatory definitions and the amount in effect at consummation.
• Lenders and lessors may wish to test disclosures, notices, document generation, and exception handling for transactions close to $73,400, including boundary cases and rounding controls.
• Compliance teams should consider retaining the prior $71,900 threshold for transactions governed by the 2025 threshold and applying $73,400 only to transactions covered by the 2026 period.
• Mortgage and private education lending teams should consider confirming that their systems do not incorrectly treat the $73,400 threshold as an exemption, because those Regulation Z categories remain covered regardless of loan amount.
• Firms may wish to document the annual CPI-W-based threshold change in regulatory inventories, procedures, monitoring scripts, and quality-assurance testing. Independent commentary from Sheppard Mullin characterized the change as an inflation-driven update to the exemption amount rather than a substantive change to TILA or CLA coverage, which supports focusing implementation on system and classification controls.

What changed

Effective January 1, 2026, the Regulation Z exemption threshold under 12 CFR 1026.3(b) and the Regulation M exemption threshold under 12 CFR 1013.2(e) increased to $73,400 from $71,900. The adjustment is based on the annual percentage increase in CPI-W as of June 1, 2025, reported as 2.1%, and is reflected in Regulation Z comment 3(b)-3.xvii and Regulation M comment 2(e)-11.xvii. Regulation Z and Regulation M generally apply to covered consumer credit transactions and consumer leases at or below $73,400; transactions above that amount are generally outside the relevant coverage.