The CFPB recently adjusted the asset-size exemption threshold for banks, savings associations, and credit unions collecting data in 2020 and amended the official commentary that interprets the requirements of HMDA (Regulation C). The new asset-size exemption threshold is $47 million—an increase from $46 million in 2019. Banks, savings associations, and credit unions with assets at or below $47 million are exempt from collecting data for 2020.
Similarly, the CFPB amended the commentary interpreting the requirements of TILA (Regulation Z) and adjusted the asset-size threshold for certain creditors to qualify for an exemption to the requirement to establish an escrow account for a higher-priced mortgage loan. The exemption threshold adjusted to $2.202 billion for 2020, from $2.167 billion in 2019.