On December 27, 2024 the Consumer Financial Protection Bureau (CFPB) amended the Home Mortgage Disclosure Act (Regulation C) and on December 23, 2024 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 increases or decreases in the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W) in November, which had an increase of 2.9%.
- Based on the adjustments, the HMDA asset-size exemption for banks, savings associations and credit unions will go from $56 million in 2024 to $58 million in 2025. As a result, institutions with assets of $58 million or less as of December 31, 2024 are exempt from collecting HMDA data in 2025.
- Based on the HPML escrow adjustments, the Regulation Z asset-size exemption for creditors will increase to $2.717 billion from the $2.640 billion in place for 2024. 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 2025, 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 in 2022 for Insured Institutions added a new threshold of $10 billion. This figure is also getting an increase to $12.179 billion for 2025, up from 11.835 billion in 2024. 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, 2025.
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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