The CFPB last week announced the asset-size exemption threshold for institutions under Regulation C, which implements the Home Mortgage Disclosure Act. Effective Dec. 31, the exemption threshold increased to $46 million from $45 million.
The adjustment is based on the 2.6 percent increase in the average of the Consumer Price Index for Urban Wage Earners and Clerical Workers for the 12-month period ending in November 2018. Therefore, credit unions with assets of $46 million or less as of Dec. 31, 2018, are exempt from collecting Home Mortgage Disclosure data in 2019.
The asset threshold is one of five criteria that must be satisfied for a credit union to have to report HMDA data.
The bureau has also announced the asset-size exemption thresholds for certain creditors under the escrow requirements and small creditor portfolio and balloon-payment qualified mortgage requirements, as well as the small creditor exemption from the prohibition against balloon-payment high-cost mortgages under Regulation Z.
Effective Dec. 31, the exemption threshold increased to $2.167 billion from $2.112 billion. Creditors with assets of less than $2.167 billion 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, 2020.