News & Analysis as of

Mortgages Exemptions

The term "mortgage" typically refers to a mortgage loan.  A mortgage loan is a financing instrument where an individual or business borrows money to purchase property (usually real property) and... more +
The term "mortgage" typically refers to a mortgage loan.  A mortgage loan is a financing instrument where an individual or business borrows money to purchase property (usually real property) and uses that property as collateral for the loan. less -
Ballard Spahr LLP

CFPB/Fed/OCC increase exemption thresholds for appraisal requirement, Regs Z and M

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The CFPB, Fed, and OCC have announced that they are increasing exemption thresholds that are subject to annual inflation adjustments.  Effective January 1, 2025 through December 31, 2025, these exemption thresholds are...more

Troutman Pepper

Federal Agencies Announce Increased Regulations Z and M Dollar Thresholds for Exempt Consumer Credit and Lease Transactions, and...

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On October 4, the Consumer Financial Protection Bureau (CFPB) and the Federal Reserve Board (Fed) announced increased dollar thresholds used to determine whether certain consumer credit and lease transactions in 2025 are...more

Orrick, Herrington & Sutcliffe LLP

CFPB adjusts asset-size exemption thresholds for Regulations C and Z

On December 18, the CFPB adjusted the asset-size exemption thresholds for Regulation C (as part of the Home Mortgage Disclosure Act) and Regulation Z (as part of TILA), based on a 4.1 percent increase in the average...more

Ballard Spahr LLP

CFPB/Fed/OCC increase exemption thresholds for appraisal requirement, Regs Z and M (UPDATED)

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The CFPB, Fed, and OCC have announced that they are increasing three exemption thresholds that are subject to annual inflation adjustments.  Effective January 1, 2024 through December 31, 2024, these exemption thresholds are...more

Troutman Pepper

Federal Agencies Announce Increased Regulations Z and M Dollar Thresholds for Exempt Consumer Credit and Lease Transactions, and...

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On November 13, the Consumer Financial Protection Bureau (CFPB) and the Federal Reserve Board (Fed) announced increased dollar thresholds used to determine whether certain consumer credit and lease transactions in 2024 are...more

Ballard Spahr LLP

Arizona Mortgage Broker Certificate of Exemption

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Effective September 24, 2022, an Arizona Mortgage Broker applicant may now seek a certificate of exemption through the NMLS from Arizona’s in-state requirement for a Responsible Individual (Arizona Mortgage Broker Responsible...more

Sheppard Mullin Richter & Hampton LLP

It’s Time to (Carefully) Secure that Guaranty

The 2021 increase to California’s homestead exemption to up to $600,000 stands to change the legal and economic relationship of guarantors with their lenders and vendors who make loans or sell goods or services on...more

Ballard Spahr LLP

CFPB Finalizes Rule 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), passed in June 2018, created an exemption from the requirement to maintain an escrow account in connection with a...more

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CFPB Adjusts HMDA and TILA Asset Exemption Thresholds

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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 - Finance 20/20

Agencies Announce Threshold for Smaller Loan Exemption from Appraisal Requirements for Higher-Priced Mortgage Loans

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On November 18, the Consumer Financial Protection Bureau (CFPB), the Federal Reserve Board (FRB), and the Office of the Comptroller of the Currency (OCC) (collectively, the “Agencies”) announced that the threshold for...more

Goodwin

Financial Services Weekly Roundup: Code Libor – SEC And OCIE Issue Risk Alert In Preparation Of Libor Discontinuation

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In This Issue. The Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert about the scope and content of examinations OCIE plans to conduct of various...more

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Alaska Exempts Nonprofit Organizations From Mortgage Lender Licensing Requirements

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The Alaska Department of Commerce, Community, and Economic Development recently adopted amendments to its mortgage lending regulations to exempt bona fide nonprofit organizations from the licensing requirement....more

Alston & Bird

Agencies Raise Appraisal Threshold Exemption

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A&B ABstract: A new rule from the federal banking regulators reduces the number of residential mortgage transactions for which an appraisal is required. ...more

Ballard Spahr LLP

Federal Banking Agencies Increase Transaction Value Appraisal Exemption

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As we previously reported, last November the FDIC, Federal Reserve Board and Comptroller of the Currency (the federal banking agencies) proposed a rule to implement a rural residential property appraisal exemption under the...more

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Minnesota Revises Licensing Requirements Effective August 1, 2019

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Minnesota has revised its Residential Mortgage Originator and Servicer Licensing Act to provide an exemption from residential mortgage originator licensure requirements for a "manufactured home dealer" and "manufactured home...more

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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

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Banking Agencies Propose Rule To Increase Appraisal Exemption Transaction Value

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The FDIC, Federal Reserve Board and Comptroller of the Currency are proposing a rule to implement a rural property appraisal exemption under the Economic Growth, Regulatory Relief, and Consumer Protection Act (the Act) and...more

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CFPB Revises HMDA Small Entity Compliance Guide

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The CFPB recently issued a revised version of the Home Mortgage Disclosure (Regulation C) Small Entity Compliance Guide to reflect a partial exemption to Home Mortgage Disclosure Act (HMDA) requirements made by the Economic...more

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CFPB Provides Additional Guidance on HMDA Partial Exemption

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The CFPB recently released an interpretive and procedural rule to implement and clarify the partial exemption from the Home Mortgage Disclosure Act (HMDA) adopted in the Economic Growth, Regulatory Relief, and Consumer...more

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Washington Amends Mortgage Servicing Regulations

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The Washington Department of Financial Institutions (DFI) amended its regulations under the Consumer Loan Act, effective September 1, 2018. Changes are made to a variety of provisions, including licensing coverage and various...more

Ballard Spahr LLP

CFPB Addresses Partial HMDA Exemption for Certain Depository Lenders

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The Consumer Financial Protection Bureau (CFPB) recently issued a statement regarding the partial exemption from Home Mortgage Disclosure Act (HMDA) reporting requirements for certain lower mortgage volume depository...more

Ballard Spahr LLP

CFPB/Fed/OCC increase exemption thresholds for appraisal requirement, Regs Z and M (UPDATED)

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The CFPB, Fed, and OCC have published notices in the Federal Register announcing that they are increasing three exemption thresholds that are subject to annual inflation adjustments. Effective January 1, 2018 through...more

Ballard Spahr LLP

FCC Denies TCPA Exemption for Mortgage Servicing Calls

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The Federal Communications Commission (FCC) has denied the petition filed by the Mortgage Bankers Association (MBA) seeking an exemption from the prior express consent requirement of the Telephone Consumer Protection Act...more

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CFPB announces annual adjustments to HMDA/TILA asset-size exemption thresholds

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The CFPB has announced annual adjustments to two asset-size exemption thresholds. First, the CFPB has made no change to the asset-size exemption threshold under HMDA/Regulation C which is currently set at $44 million. ...more

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CFPB amends commentary on adjustments to exemption thresholds; makes no changes to 2017 thresholds

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The CFPB has adopted changes to its Reg Z commentary to memorialize the calculation methods used each year to adjust the thresholds for exempt consumer credit transactions and for transactions exempt from the special...more

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