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.