HMDA and TILA annual adjustments

The CFPB has announced two final rules with annual threshold adjustments under the implementing regulations for the Home Mortgage Disclosure Act (HMDA) and the Truth in Lending Act (TILA).

The HMDA asset-size exemption threshold under Regulation C is unchanged at $44 million. Institutions with assets of $44 million or less as of December 31, 2015, are exempt from collecting HMDA data in 2016.

The TILA criterion for exemption under Regulation Z’s HPML escrow requirements decreased from $2.060 billion to $2.052 billion for 2016. As a result, these creditors with assets of less than $2.052 billion (including assets of certain affiliates) as of December 31, 2015, that also meet other requirements of Regulation Z will be exempt from the requirement to establish escrow accounts for higher-priced mortgage loans in 2016.

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