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Read articles below for analysis and discussion of recent trends by BM&G’s industry experts.

Asset-size Thresholds Revised for HMDA and TILA in 2018

In the December 27, 2017 issue of the Federal Register, the following annually revised asset-size thresholds were published to be effective January 1, 2018: Home Mortgage Disclosure Act/Regulation C (82 FR 61145) The CFPB has added comment -2 under the definition “Financial institution” in §1003.2(g) of the Staff Commentary to Regulation C (12 CFR part 1003) to increase the asset-size exemption threshold for banks, savings associations, and credit unions for HMDA data collected in 2018 to $45 million. Therefore, effective January 1, 2018, banks, savings associations, and credit unions with assets at or below $45 million as of December 31, 2017, are exempt from collecting HMDA data for 2018. (Note: An institution’s exemption from collecting HMDA data in 2018 does not affect its responsibility to report data it was required to collect in 2017.)

Updated Exemption Thresholds for Consumer Credit Transactions and Higher-

In the November 9, 2017 issue of the Federal Register (82 FR 51977) (click here), the Board of Governors of the Federal Reserve System (“Board”) and the Bureau of Consumer Financial Protection (“CFPB”) published a final rule increasing the threshold for consumer credit transactions exempt from the Truth In Lending Act. Also in the November 9, 2017 issue of the Federal Register (82 FR 51973) (click here), the Board, CFPB and the Office of the Comptroller of the Treasury (“OCC”) published a final rule increasing the threshold exemption from required appraisals for higher-priced mortgage loans. In both instances, the final rules will take effect on January 1, 2018.

Updated Exemption Thresholds for Consumer Credit Transactions and Higher-Priced Mortgage Loan Appraisals

In the November 30, 2016 issue of the Federal Register (81 FR 86260) (click here), the Board of Governors of the Federal Reserve System (“Board”) and the Bureau of Consumer Financial Protection (“CFPB”) announced the final rule updating the threshold for consumer credit transactions exempt from the Truth In Lending Act. Also in the November 30, 2016 issue of the Federal Register (81 FR 86250) (click here), the Board, CFPB and the Office of the Comptroller of the Treasury (“OCC”) announced the final rule updating the threshold for exemptions from required appraisals for higher-priced mortgage loans. In both instances, the final rules will take effect on January 1, 2017, and the exemption thresholds will remain the same for 2017 at greater than $54,600 for exempt consumer credit transactions and at $25,500 or less for the exemption to the appraisal requirement for higher-priced mortgage loans.

CFPB Corrects Typographical Error in Supplementary Information to TRID Rule Regarding Application of Tolerances to Certain Fees and Charge

In the February 10, 2016, issue of the Federal Register (81 FR 7032, click here), the CFPB corrected a typographical error in the Supplementary Information to the TILA-RESPA Final Rule published in the December 31, 2013, issue of the Federal Register (78 FR 79730) regarding the applicability of TRID tolerances to property insurance premiums, property taxes, homeowner’s association dues, condominium fees, and cooperative fees under Section 1026.19(e)(3)(iii) of Regulation Z. On page 79830, in the first column, lines 44 through 50, the Supplementary Information to the TILA-RESPA Final Rule in the December 31, 2013, issue of the Federal Register incorrectly states: “The final rule also mirrors current Regulation X in that property insurance premiums, property taxes, homeowner’s association dues, condominium fees, and cooperative fees are subject to tolerances whether or not they are placed into an escrow, impound, reserve, or similar account.” (Emphasis added.)

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