Banks, credit unions and savings associations with assets of $47 million or less as of Dec. 31 are exempt from collecting data in 2020 under Regulation C, the federal consumer financial protection agency Monday in setting the annual asset-size threshold.
The Consumer Financial Protection Bureau (CFPB) said the $1 million upward adjustment from 2018 in the threshold was based on a 1.6% increase in the average of the CPI-W for the 12-month period ending in November 2019. The 2018 threshold was $46 million.
Also Monday, in its adjustment to Regulation Z thresholds, the bureau announced that creditors with assets of less than $2.202 billion (including assets of certain affiliates) as of Dec. 31 are exempt, if other requirements of Regulation Z also are met, from establishing escrow accounts for higher-priced mortgage loans in 2020.
The asset-size exemption threshold applies to certain creditors under the escrow requirements and small creditor portfolio and balloon-payment qualified mortgage requirements, and the small creditor exemption from the prohibition against balloon-payment high-cost mortgages under Regulation Z.
The CFPB said the asset limit will also apply during a grace period, in certain circumstances, with respect to transactions with applications received before April 1, 2021.
Like the Reg C threshold adjustment, the Reg Z adjustment is based on the 1.6% increase in the average of the CPI-W for the 12-month period ending in November 2019.
Both adjustments are effective Jan. 1.
Home Mortgage Disclosure (Regulation C) Adjustment to Asset-Size Exemption Threshold
Truth in Lending Act (Regulation Z) Adjustment to Asset-Size Exemption Threshold