The CFPB proposed amendments to Regulation Z (implementing the "Truth in Lending Act") to provide certain banks, savings institutions and credit unions an exemption from establishing escrow accounts for higher-priced mortgage loans ("HPMLs"). Under the proposal, the exemption would be available only as to an HPML secured by a "first lien on the principal dwelling of a consumer." An institution relying on the exemption must (i) have assets totaling not more than $10 billion, (ii) have provided no more than 1,000 loans secured by a first lien on a principal dwelling during the previous calendar year and (iii) meet a number of other conditions.
Comments on the proposal must be submitted within 60 days of its publication in the Federal Register.
Originally published July 06, 2020.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.