CFPB Proposal on HPML Escrow Exemptions

On 7/2/2020, the CFPB released a notice of proposed rulemaking that would change Regulation Z to provide a new exemption available to certain banks and credit unions from the requirements to establish escrow accounts for certain higher-priced mortgage loans (HPMLs). This proposal is the Bureau’s last required rule under the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA). According to the CFPB’s release, the proposed amendment generally would exempt the HPML escrow requirement for any loan made by a bank or credit union that is secured by a first lien on the principal dwelling of a consumer if the following conditions are met: 1) the institution has assets of $10 billion or less; 2) the institution and its affiliates originated 1,000 or fewer loans secured by a first lien on a principal dwelling during the preceding calendar year; and (3) certain other criteria are met.

The full notice of proposed rulemaking can be found here.

CFPB Sues for UDAAP Violations

CFPB Spring 2020 Rulemaking Agenda