On January 7, the CFPB amended the official commentary to Regulation Z (which implements TILA) and Regulation C (which implements the HMDA) by updating the asset-size exemption thresholds for financial institutions. These adjustments were based on a 2.5 percent increase in the average of the consumer price index for the 12-month period ending in November 2025.
Under the revised official commentary to Regulation Z, the exemption threshold for certain creditors from the requirement to establish escrow accounts for higher-priced mortgage loans increased to $2.785 billion, and for insured depository institutions and credit unions, the threshold rose to $12.485 billion. These adjustments apply to transactions in 2026 and to loans consummated in 2027 with applications received before April 1, 2027.
The CFPB’s revised official commentary to Regulation C raises the HMDA asset-size exemption threshold for banks, savings associations, and credit unions to $59 million for 2026. The rule stated institutions with assets of $59 million or less as of December 31, 2025, are exempt from collecting HMDA data in 2026.
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