David Mulkerin

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CFPB Issues Changes to Rule on Higher-Priced Mortgage Loan Escrow Exemption

On February 17, 2021, the CFPB published a final rule 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 final rule also removed

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regulations book

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

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HPML Appraisal & Regulation Z and Regulation M Exemption Amounts Hold Steady for 2021

The Federal Reserve Board and the Consumer Financial Protection Bureau jointly issued an increase in the exemption thresholds for Regulation Z and Regulation M, which are tied to the Consumer Price Index. Loans or leases at or below the thresholds are subject to the protections of the regulations. The regulators have released the new index

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