CFPB Increases 2019 Asset-Size HMDA Thresholds, Reg Z Small-Creditor Status

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The Consumer Financial Protection Bureau (CFPB) has increased the maximum asset-size of credit unions exempt from collecting Home Mortgage Disclosure Act (HMDA) (Regulation C) data in 2019. It also raised the cap under which credit unions can be considered small creditors for certain escrow and qualified mortgage requirements under the Truth in Lending Act (Regulation Z). The December 31, 2018, issuances reflect annual adjustments required by HMDA and Regulation Z, respectively.

Credit unions with assets of $46 million or less as of Dec. 31, 2018, are exempt from collecting 2019 HMDA data. 

Click here to review the updated HMDA data thresholds.

Regulation Z now provides exemptions to small creditors with assets less than $2.167 billion from maintaining mortgage escrow accounts if they comply with some requirements. Similar sized credit unions can also originate qualified mortgages without the need to comply with some Regulation Z requirements, so long as they fulfill specified conditions. 

Click here to review the new Regulation Z exemptions.

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