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CRA Asset-size Thresholds Announced for 2023

The annual CRA asset-size thresholds for covered financial institutions were announced December 19, 2022 by the FDIC and FRB and on December 28 by the OCC applicable for 2023. The cutoff adjustments are based on the change in the CPI (Consumer Price Index) for each 12-month period ending in November, rounded to the nearest million. …

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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 …

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New Threshold Amounts for 2023 under Regulation Z CARD Act, HOEPA and QM Sections

Based on the 8.9% increase in the Consumer Price Index (CPI-W) in effect on June 1, 2022, the Consumer Financial Protection Bureau (CFPB) released a number of new thresholds which go into effect on January 1, 2023. They include: Additionally, these changes affected the HOEPA threshold amounts found under 1026.32 based on the 8.3% increase …

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heloc

CFPB Releases Revision to Regulation Z HELOC Booklet

The Consumer Financial Protection Bureau (CFPB) announced the availability of an updated consumer publication, “What You Should Know about Home Equity Lines of Credit,” also known as the HELOC booklet, required by the Truth in Lending Act/Regulation Z (1026.40(e)). The CFPB states this version of the HELOC booklet (dated 8/22) is updated “to align with …

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HMDA Reporting Threshold Changes Due to Court Ruling

On April 16, 2020, the CFPB released a final rule affecting the thresholds for HMDA reporting. Effective July 1, 2020 the number of closed-end loans originated to be considered a “financial institution” was increased from 25 to 100 for each of the two preceding years for both depository and non-depository institutions. On September 23, 2022, …

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HPML Appraisal & Regulation Z and Regulation M Exemption Dollar Thresholds for 2023

On October 13, 2022 the Federal Reserve Board and the Consumer Financial Protection Bureau jointly issued an increase in the exemption thresholds for Regulation Z and Regulation M exemptions, 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 …

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FinCEN Issues Final Rule for Beneficial Ownership Reporting

On September 29, 2022, FinCEN issued a final rule for Beneficial Ownership Reporting to support law enforcement efforts. The rule establishes timeframes for legal entities to report beneficial ownership information FinCEN as required by the Corporate Transparency Act (CTA). According to the publication, FinCEN will have rulemakings to: Establish rules for who may access the …

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