ARTICLE
22 January 2021

CFPB Adopts Exemption On Escrow Accounts For Higher-Priced Mortgage Loans

CW
Cadwalader, Wickersham & Taft LLP
Contributor
Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
The CFPB adopted amendments to Regulation Z (Truth in Lending) to provide certain insured depository institutions and credit unions with an exemption from establishing escrow accounts for higher-priced mortgage loans.
United States Finance and Banking
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The CFPB adopted amendments to Regulation Z (Truth in Lending) to provide certain insured depository institutions and credit unions with an exemption from establishing escrow accounts for higher-priced mortgage loans ("HPMLs").

The exemption will be available only to an HPML secured by a "first lien on the principal dwelling of a consumer." (See previous coverage.) 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 the existing HPML escrow exemption criteria.

The final rule will go into effect on the date of its publication in the Federal Register.

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.

ARTICLE
22 January 2021

CFPB Adopts Exemption On Escrow Accounts For Higher-Priced Mortgage Loans

United States Finance and Banking
Contributor
Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
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