CFPB Publishes Updated List of Rural, Underserved Counties for 2018

The CFPB has updated and published its list of rural and underserved counties for 2018 for lenders to use in determining whether certain TILA requirements apply.

The CFPB has also updated its rural and underserved areas tool (the “Tool”). The Tool is designed to assist lenders in determining which properties are located in a “rural” or “underserved” area, as defined.  According to the CFPB, a lender may rely on the Tool to provide a safe harbor determination that a property is located in a rural or underserved area.

According to the CFPB, the Tool is more comprehensive than the lists because the lists reflect rural status only at the county level, while the Tool includes both locations that are rural because they lie in rural (non-urban) census blocks and locations that are rural because they lie in rural counties.  The Tool, however, is not applicable to the exemption from the additional appraisal requirement for certain higher-priced mortgage loans, which exemption is based on “rural county” and not “rural area.”

U.S. territories are included as rural areas in their entities.  The U.S. Census Bureau treats U.S. territories as counties and they are not metropolitan statistical areas or micropolitan statistical areas adjacent to metropolitan statistical areas.  U.S. territories include: Guam, the Commonwealth of the Northern Mariana Islands, American Samoa, and the U.S. Virgin Islands.