I believe you missed Comment 2(e)-9(iii), which sets the threshold for calendar year 2012. It's a rule change adopted by the Board 6/20/11 (76 FR 35721), with an effective date of 1/1/2012.
Since the Bureau won't have an opportunity to go back to July 2011 to set the 2012 threshold, I believe it should have been included in the interim final rule.
Comment on CFPB-2011-0026-0001
This is comment on Rule
Consumer Leasing (Regulation M)
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