The asset-size thresholds for institutions subject to Home Mortgage Disclosure Act (HMDA) reporting and Truth in Lending Act (TILA) escrows (for higher-priced mortgage loans) are higher as of Wednesday, according to two Federal Register notices.
The Consumer Financial Protection Bureau (CFPB) revised its official commentary under Regulation C (HMDA) to show the exemption threshold for banks, savings associations, and credit unions subject to the requirements is $59 million, up from $58 million in 2024. Institutions with assets less than $59 million as of Dec. 31, 2025, are exempt from HMDA data collection in 2026, one notice says.
The bureau’s other notice says its Reg Z (TILA) commentary is revised to show that the exemption threshold from the HPML escrow requirement for creditors and affiliates that regularly extended covered loans secured by first liens is adjusted to $2.785 billion (up from $12.179 billion) ; and the exemption threshold for certain insured depository institutions and insured credit unions with assets of $10 billion or less is adjusted to $12.485 billion (up from $12.179 billion.).
Both the Reg C and Reg Z changes were made based on consumer price index changes for the 12-month period ending in November 2025.
Federal Register notice (HMDA)
Federal Register notice (TILA)
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