The asset-size exemption thresholds for financial institutions required to collect Home Mortgage Disclosure Act (HMDA) data and, separately, to establish escrow accounts for higher-priced mortgage loans will rise in 2024, according to Federal Register notices published Thursday.
The thresholds, set by the Consumer Financial Protection Bureau (CFPB) based on changes in the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI–W). They are applied by the CFPB’s Regulation C (HMDA), which includes mortgage data collection and reporting requirements; and Regulation Z (Truth in Lending Act, or TILA), which includes requirements affecting higher-priced mortgage loans (HPMLs).
Thursday’s notices show that effective Jan. 1:
- Institutions with assets of $56 million (up from $54 million) or less are exempt from HMDA data collection in 2024.
- Creditors and their affiliates that regularly extended covered transactions secured by first liens and that have less than $2.640 billion in assets (up from $2.537 billion) are exempt from the Regulation Z requirement to establish an escrow accounts for HPMLs.
- Banks and credit unions with assets of less than $11.835 billion (up from $11.374 billion) are exempt from the Reg C requirement to establish escrow accounts for HPMLs.