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CFPB increases 2019 asset-size thresholds for HMDA Reporting, Reg. Z Small-Creditor Status

Jan 25, 2019
The Consumer Financial Protection Bureau yesterday announced increases to the maximum asset size of credit unions exempt from collecting Home Mortgage Disclosure Act (Regulation C) data in 2019. It also raised the cap under which credit unions can be considered small creditors for certain escrow and qualified mortgage requirements under the Truth in Lending Act (Regulation Z). The Dec. 31, 2018, issuances reflect annual adjustments required by HMDA and Regulation Z, respectively.

The Consumer Financial Protection Bureau yesterday announced increases to the maximum asset size of credit unions exempt from collecting Home Mortgage Disclosure Act (Regulation C) data in 2019. It also raised the cap under which credit unions can be considered small creditors for certain escrow and qualified mortgage requirements under the Truth in Lending Act (Regulation Z). The Dec. 31, 2018, issuances reflect annual adjustments required by HMDA and Regulation Z, respectively.

Credit unions with assets of $46 million or less as of Dec. 31, 2018, are exempt from collecting 2019 HMDA data.

Review the Updated HMDA Data Thresholds

Regulation Z now provides exemptions to small creditors with assets less than $2.167 billion from maintaining mortgage escrow accounts if they comply with some requirements. Similar sized credit unions can also originate qualified mortgages without the need to comply with some Regulation Z requirements, so long as they fulfill specified conditions.

Review the New Regulation Z Exemptions

Learn more about the Home Mortgage Disclosure Act by accessing the NCUA’s Fair Lending Compliance Resources webpage, and the Truth in Lending Act’s mortgage provisions at the Dodd-Frank Mortgage Lending Resources.