News & Analysis as of

High-Priced Mortgage Loans (HPML)

Ballard Spahr LLP

CFPB Adjusts HPML Asset Exemption Threshold

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The CFPB recently issued a final rule increasing the asset exemption threshold for the Truth in Lending Act (TILA) requirement to maintain an escrow account for a higher-priced mortgage loan (HPML)....more

Husch Blackwell LLP

CFPB Finalizes Rule on Residential PACE Loans

Husch Blackwell LLP on

On December 17, 2024, the Consumer Financial Protection Bureau (CFPB) issued its final rule implementing Section 307 of the 2018 Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) and amending...more

Ballard Spahr LLP

CFPB Adjusts HMDA and HPML Asset Exemption Thresholds (UPDATED)

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The CFPB recently issued a final rule increasing the asset exemption threshold under the Home Mortgage Disclosure Act (HMDA) and a final rule increasing the asset exemption threshold for the Truth in Lending Act (TILA)...more

Orrick, Herrington & Sutcliffe LLP

Agencies finalize 2024 HPML smaller loan exemption threshold

On November 13, the CFPB, OCC, and the Fed published final amendments to the official interpretations for regulations implementing Section 129H of TILA, which establishes special appraisal requirements for “higher-risk...more

Ballard Spahr LLP

CFPB Adjusts HMDA and HPML Asset Exemption Thresholds

Ballard Spahr LLP on

The CFPB recently issued a final rule increasing the asset exemption threshold under the Home Mortgage Disclosure Act (HMDA) and a final rule increasing the asset exemption threshold for the Truth in Lending Act (TILA)...more

Ballard Spahr LLP

CFPB Proposes to Implement Growth Act Escrow Exemption for Higher-Priced Mortgage Loans

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As previously reported, the Economic Growth, Regulatory Relief, and Consumer Protection Act (Growth Act), also known as S.2155, directs the CFPB to implement an exemption from the mandatory escrow account requirement for...more

Ballard Spahr LLP

CFPB Publishes 2019 Final Lists of 'Rural' and 'Rural or Underserved' Counties

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The CFPB has published its 2019 final lists of "rural" and "rural or underserved" counties on its website. The CFPB has previously posted lists of such counties for calendar years 2011-2018....more

Ballard Spahr LLP

CFPB publishes 2019 final lists of rural and rural or underserved counties

Ballard Spahr LLP on

The CFPB has published its 2019 final lists of Rural and Rural or Underserved Counties on its website. The CFPB has previously posted lists of such counties for calendar years 2011-2018....more

Morrison & Foerster LLP

CFPB, OCC, and Federal Reserve Propose Clarifications to Small Loan Exemption from HPML Appraisal Requirements

On August 4, 2016, the Consumer Financial Protection Bureau (“CFPB”), the Office of the Comptroller of the Currency (“OCC”), and the Board of Governors of the Federal Reserve System (“Federal Reserve”) (together, the...more

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