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HMDA and HPML Thresholds Bumped Up for 2020

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 due 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 $46 million to $47 million, which reflects the 1.6% increase in the CPI from 2019. As a result, these institutions with assets of $47 million or less as of December 31, 2019 are exempt from collecting HMDA data in 2019.
  • Based on the HPML escrow adjustments, the Regulation Z asset-size exemption for banks, savings associations and credit unions will increase to $2.202 billion, from the $2.167 billion in place for 2019. 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 2020. o 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, 2020. Keep an eye out for the CRA thresholds, which should be out soon!

Does your Bank now meet the new HMDA threshold? Contact TCA today at 1-800-934-7347 or email [email protected] to consult with a compliance expert today for A Better Way to comply.

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