Pub. 9 2019 Issue 1

17 ISSUE 1. 2019 The first phase of the expanded rules provides enhanced access to same-day ACH transactions. It allows Same-Day ACH transactions to be submitted for an additional two hours each and every business day. This phase becomes effective on Sep- tember 20, 2019. The second phase of the expanded rules ups the per-transaction dollar limit from $25,000 to $100,000. This means that a single Same-Day ACH transaction will be limited to not being over $100,000. Any ACH transactions over that $100,000 limit won’t be rejected, though. They will just be pro- cessed for next-day settlement rather than Same-Day processing. This phase becomes effective on March 20, 2020. The third and final phase increases the speed of funds availability for certain, specific Same-Day ACH transactions and certain next-day ACH credits. This phase becomes effective on September 18, 2020. Next on the agenda is the set of TIL threshold adjustments. Now, for seasoned compliance professionals, you know a TIL adjustment is not all that novel. However, they are important and worth mentioning. These adjustments affect open-end consum- er credit plans under the CARD Act in that the adjusted dollar amount for the safe harbor in respect to a first violation penalty fee will increase to $28 – up $1 from $27. Under that same CARD Act umbrella, the safe harbor for a subsequent violation penalty fee will also increase $1 to $39. For HOEPA loans, the adjusted total loan threshold will be $21,459, and the adjusted points-and-fees dollar trigger will be $1,077. Finally, the thresh- old adjustments for qualified mortgages are as follows: “the maximum thresholds for total points and fees in 2019 will be 3 percent of the total loan amount for a loan greater than or equal to $107,747; $3,232 for a loan amount greater than or equal to $64,648 but less than $107,747; 5 percent of the total loan amount for a loan greater than or equal to $21,549 but less than $64,648; $1,077 for a loan amount greater than or equal to $13,468 but less than $21,549; and 8 percent of the total loan amount for a loan amount less than $13,468.” Notably, however, the threshold that triggers the disclosure requirement for minimum interest charges remains unchanged. It will keep steady at $1.00 in 2019. These threshold adjustments become effective on January 1, 2019. What to Expect w Continued from page 19 Next on the agenda is the set of TIL threshold adjustments. Now, for seasoned compli- ance professionals, you know a TIL adjustment is not all that novel. However, they are important and worth mentioning. These adjustments affect open-end consumer credit plans under the CARD Act in that the adjusted dollar amount for the safe harbor in respect to a first violation penalty fee will increase to $28 – up $1 from $27