Archive

CFPB ISSUES HPML ESCROW EXEMPTION

On January 19. 2021, the Consumer Financial Protection Bureau (CFPB) issued a final rule amending section 1026.35 of Regulation Z to implement a requirement of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA). The final rule exempts certain insured depository institutions and insured credit unions from the requirement to establish escrow accounts for certain higher-priced mortgage loans (HPMLs). The rule will take effect on publication in the Federal Register. It exempts from the HPML escrow […]

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HPML ESCROW EXEMPTION THRESHOLD INCREASED FOR 2021

For 2021, the CFPB amended the official commentary that interprets the requirements of Regulation Z (Truth in Lending) to reflect a change in the asset size threshold for certain creditors to qualify for an exemption to the requirement to establish an escrow account for a higher-priced mortgage loan (HPML). The exemption threshold is adjusted to increase to $2.230 billion from $2.202 billion. Creditors with assets of less than $2.230 billion (including assets of certain affiliates) […]

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CFPB RELEASES RURAL AND UNDERSERVED AREAS TOOL

This week the Consumer Financial Protection Bureau (CFPB) issued its Rural and Underserved Areas Tool linked here https://www.consumerfinance.gov/rural-or-underserved-tool/. The tool is designed to assist creditors in determining if properties are located in a rural or underserved area and eligible for certain exemptions from various requirements provided to certain small creditors under the CFPB’s mortgage rules. The Rural and Underserved Areas Tool is a the result of a final rule approved by the CFPB on September […]

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FLOOD RULE CONUNDRUM PART II: CONSENSUS AMONG AGENCIES ON SMALL LENDER EXCEPTION

It has been over seven weeks since the Agencies (FRB, OCC, FDIC, NCUA, and FCA) issued a joint final rule to modify existing flood regulations. And until this week the Agencies had inconsistent opinions about how the small lender escrow exception will apply to lenders that were required to escrow under Regulation Z’s Higher Priced Mortgage Loan (HPML) rules. This week we learned some good news – it appears we now have a consensus among […]

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