A CFPB proposal to amend Regulation Z (implementing the Truth in Lending Act) to provide an exemption from establishing escrow accounts for higher-priced mortgage loans ("HPMLs") was published in the Federal Register. Comments on the proposal must be submitted by September 21, 2020.
Under the proposal, the exemption would 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 other conditions.
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