HMDA, TILA threshold changes for 2019 noted in NCUA message to credit unions

The federal credit union regulator used its “CU Express” news service Thursday to tell the boards and CEOs of federally insured credit unions about recent changes in threshold amounts that determine mortgage reporting, escrow and qualified mortgage requirements for 2019.

In its message, the National Credit Union Administration (NCUA) noted the Consumer Financial Protection Bureau’s (CFPB) increase to $46 million in the maximum asset-size of credit unions and other lenders exempt from collecting Home Mortgage Disclosure Act (HMDA, implemented by Regulation C) data in 2019.

The NCUA also notes the bureau’s increase in the cap under which credit unions can be considered “small creditors” for certain escrow and qualified mortgage requirements under the Truth in Lending Act (TILA, implemented by Regulation Z). With that change, creditors with assets less than $2.167 billion that meet certain conditions are exempted in 2019 from having to maintain escrow accounts for higher-priced mortgage loans. This threshold also applies for small-creditor portfolio and balloon-payment qualified mortgages under Reg Z.

The HMDA and TILA threshold adjustments were signed Dec. 20 by CFPB Director Kathleen (“Kathy”) Kraninger; notices are pending publication in the Federal Register but carry an “applicability” date of Jan. 1, 2019.

NCUA addresses HMDA requirements via its Fair Lending Compliance Resources webpage; TILA mortgage requirements are addressed via the agency’s Dodd-Frank Mortgage Lending Resources page.

RR: Kraninger signs new-year HMDA, escrow exemption threshold adjustments (Jan. 4, 2019)

Home Mortgage Disclosure (Regulation C) Adjustment to Asset-Size Exemption Threshold

Home Mortgage Disclosure (Regulation C) Adjustment to Asset-Size Exemption Threshold