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HMDA and HPML Thresholds Bumped Up for 2021

The Consumer Financial Protection Bureau (CFPB) amended the Home Mortgage Disclosure Act (Regulation C) and the Truth in Lending Act (Regulation Z), adjusting the asset-size exemption thresholds for banks, savings associations, and credit unions. Like the CRA thresholds, the adjustments are pegged to the annual percentage increase in the Consumer Price Index for Urban Wage Earners and Clerical Workers.

  • Based on the adjustments, the HMDA asset-size exemption for banks, savings associations and credit unions will go from $47 million to $48 million, which reflects the 1.3% increase in the CPI from 2020. As a result, these institutions with assets of $48 million or less as of December 31, 2020 are exempt from collecting HMDA data in 2020.
  • Based on the HPML escrow adjustments, the Regulation Z asset-size exemption for banks, savings associations and credit unions will increase to $2.230 billion from the $2.202 billion in place for 2020. The rule applies to whether a creditor is eligible for exemption from establishing an escrow account for HPML loans (§1026.35(b)(2)(iii)(C)) in 2021.
    • This threshold change also affects the small creditor and balloon payment Qualified Mortgage thresholds under §1026.43(e)(5) and §1026.43(f)(1), respectively.

The rules will be effective January 1, 2021.

Does your Bank now meet the new HMDA threshold? Contact TCA today at [email protected] or at 800-934-7347 to consult with a compliance expert for A Better Way to comply.

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