CFPB Adjusts Asset-Size Exemption Threshold under Regulation Z

The CFPB recently announced an adjustment to the asset-size threshold under Regulation Z that a creditor must fall below to qualify for an exemption from the requirement to establish escrow accounts to pay property taxes and insurance premiums for first-lien higher-priced mortgage loans. The adjustment became effective January 1, 2018.

The adjustment, which is based on the annual percentage change in the average of the Consumer Price Index, increases the asset-size threshold from $2.069 billion to $2.112 billion. Accordingly, creditors with assets of less than $2.112 billion (including assets of certain affiliates) on December 31, 2017 are exempt, if certain other requirements under Regulation Z are also met, from the requirement to establish escrow accounts for first-lien higher-priced mortgage loans in 2018.

The adjustment also increases the similar Regulation Z threshold for small-creditor portfolio and balloon-payment qualified mortgages.

The notice can be viewed here: https://www.federalregister.gov/documents/2017/12/27/2017-27897/truth-in-lending-act-regulation-z-adjustment-to-asset-size-exemption-threshold.