CFPB Increases Asset-Size Thresholds Under HMDA, TILA


On December 30, the CFPB announced final rules adjusting the asset-size thresholds under Regulation C (HMDA) and Regulation Z (TILA). Both rules take effect on January 1, 2014.

HMDA and Regulation C require certain lenders to collect and report data about mortgage application, origination, and purchase activity, and make such data available to the public. Institutions that have an asset level below a certain dollar threshold are exempt from the requirements of Regulation C. The final rule increases the asset-size exemption threshold for banks, savings associations, and credit unions from $42 million to $43 million, thereby exempting institutions with assets of $43 million or less as of December 31, 2013, from collecting HDMA data in 2014.

TILA and Regulation Z, among other things, require creditors to establish escrow accounts when originating higher-priced mortgage loans. However, TILA exempts certain entities from this requirement, including entities that meet an asset-size threshold established by the CFPB. The final rule increases this asset-size exemption threshold from $2 billion to $2.028 billion, thereby exempting creditors with assets of $2.028 billion or less as of December 31, 2013, from the requirement to establish escrow accounts for higher-priced mortgage loans in 2014.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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