2018 Threshold for Small Creditors

Regulation Z sets an annual threshold to determine small creditor status for certain rules such as Ability To Repay (ATR) and Qualified Mortgage (QM) rules, as well as Higher Priced Mortgage Loan  (HPML) escrow accounts.

In 2018, this threshold has increased to $2.112 billion from $2.069 billion in 2017.

If you have small creditor applicability questions, feel free to ask us here.

HMDA Enforcement for 2018 Data

2018 CRA Threshold Update