Regulatory Alert (22-RA-03) 2022 Truth in Lending Act (Regulation Z) Adjustment to Asset-Size Exemption Threshold

Source: NCUA

The Consumer Financial Protection Bureau (CFPB) published annual adjustments for asset-size exemption thresholds under the Truth in Lending Act (TILA), as implemented by Regulation Z, which became effective on January 1, 2022. The asset-size thresholds exempt certain credit unions from escrow account requirements for higher-priced mortgage loans and specific qualified mortgages under Regulation Z.

Regulation Z: Escrows and Small Creditor Qualified Mortgages - Asset-Size Exemption Threshold Increased to $2.336 Billion

Creditors with assets of less than $2.336 billion (including assets of certain affiliates) on December 31, 2021, are exempt from the requirement to establish escrow accounts for higher-priced mortgage loans in 2022 if other provisions of Regulation Z are also met. This asset-size threshold also applies during a grace period, in certain circumstances, with respect to transactions with applications received before April 1, 2023.

Read the Regulatory Alert