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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

by | Dec 28, 2017 | , ,

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-

by | Nov 30, 2017 | ,

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.

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