mortgage loan disclosure

HMDA and HPML Thresholds Bumped Up for 2023

On December 28, 2022, 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 (CPI-W).

  • Based on the adjustments, the HMDA asset-size exemption for banks, savings associations and credit unions will go from $50 million in 2022 to $54 million, which reflects the 8.6% increase in the CPI-W for 2022. As a result, institutions with assets of $54 million or less as of December 31, 2022 are exempt from collecting HMDA data in 2023.
  • Based on the HPML escrow adjustments, the Regulation Z asset-size exemption for creditors will increase to $2.537 billion from the $2.336 billion in place for 2022. 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 2023, assuming all other criteria are met.
  • 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 HPML escrow adjustment implemented this past March for Insured Institutions added a new threshold of $10 billion. This figure is also getting an increase to $11.374 billion for 2023, up from 10.473 billion in 2022. This limit is applicable to insured depository institutions and insured credit unions meeting certain conditions as outlined in Regulation Z.

The rules will be effective January 1, 2023.

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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