On December 19, 2019, 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 2020, the exemption threshold has increased from 2.167 billion to $2.202 billion. The adjustment is based on the 1.6 percent increase in the average of the CPI-W for the 12-month period ending in November 2019. Therefore, creditors with assets of less than $2.202 billion (including assets of certain affiliates) as of Dec. 31, 2019, are exempt, if other requirements of Regulation Z also are met, from establishing escrow accounts for higher-priced mortgage loans in 2020. This asset limit will also apply during a grace period, in certain circumstances, with respect to transactions with applications received before April 1 of 2021.
The 2020 adjustments can be found here.