CFPB Announcement: New Asset Size Thresholds

1/10/2018 - By Janet Munns, CRCM

Just three business days before the new year, on December 27, 2017 the Consumer Financial Protection Bureau (CFPB) released the following asset size thresholds for year 2018.

2018 Home Mortgage Disclosure Asset Size Exemption Threshold

For purposes of the Home Mortgage Disclosure Protection Act (HMDA) the new exemption threshold is $45 million (up from $44 million in 2017). If your institution had assets of $45 million or less as of December 31, 2017, your institution is exempt from HMDA data collection in 2018.

FR-2017-12-27 HMDA Threshold

2018 TILA Mortgage Escrow Asset Size Exemption Threshold

Not to be confused with the previously announced dollar threshold for consumer credit transactions, the CFPB has increased the 2018 asset size threshold for establishing escrow accounts for certain first-lien higher priced mortgage loans. The Truth in Lending Act (TILA) was revised in 2013 by the Dodd Frank Wall Street Reform and Consumer Protection Act to require escrow accounts for payment of property taxes and insurance premiums on certain mortgage loans. The rule includes an exemption from the escrow requirement for institutions that operate predominantly in rural or underserved areas and, meet other exemption criteria, including the asset-size threshold which is adjusted annually.  The institution asset size threshold for 2018 has increased to $2.112 billion. This will also increase the threshold for small-creditor portfolio and balloon-payment qualified mortgages under Regulation Z.

FR-2017-12-27 TILA Escrow Threshold

About the Author | Janet Munns, CRCM

Janet is a consultant in the Financial Institutions Advisory Group at Saltmarsh, Cleaveland & Gund and has been serving the financial institutions industry since 1982, focusing on compliance, operations, policies and procedures. Janet is primarily involved in performing fair lending, loan internal audit, loan compliance, and other consulting services for our financial institution clients.

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