2019 Small Creditor Thresholds Under Regulation Z

On December 31, 2018, the CFPB announced the annual adjustment to the asset size threshold for small creditors under Regulation Z.  This threshold applies to both the exemption to the requirement to establish an escrow account for higher-priced mortgage loans as well as the thresholds for small creditors to originate small-creditor portfolio and balloon-payment qualified mortgages.

For 2019, the exemption threshold has increased from 2.112 billion to $2.167 billion.  The adjustment is based on the 2.6 percent increase in the average of the CPI-W for the 12-month period ending in November 2018. Therefore, creditors with assets of less than $2.167 billion (including assets of certain affiliates) as of Dec. 31, 2018, are exempt, if other requirements of Regulation Z also are met, from establishing escrow accounts for higher-priced mortgage loans in 2019. This asset limit will also apply during a grace period, in certain circumstances, with respect to transactions with applications received before April 1 of 2020.  

The CFPB announcement can be found here.

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