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ARTICLE · 25 MARCH 2013

The CFPB's "Escrows Rule" Exempts Small Creditors In Rural Or Underserved Counties From Escrow Requirements

The Consumer Financial Protection Bureau’s Escrow Requirements under the Truth in Lending Act rule will go into effect on June 1, 2013.

United StatesConsumer Protection

The Consumer Financial Protection Bureau's ("CFPB") Escrow Requirements under the Truth in Lending Act rule ("Escrows Rule") will go into effect on June 1, 2013. The Rule amends Regulation Z (Truth in Lending) to implement certain amendments to the Truth in Lending Act made by the Dodd-Frank Act. The Escrows Rule requires certain creditors to create escrow accounts for a minimum of five years for higher-priced mortgage loans. The Rule, however, exempts high-priced mortgage loans made by certain small creditors that operate predominantly in rural or underserved counties from this requirement. Rural counties are defined by using the USDA Economic Research Service's urban influence codes, and underserved counties are defined by reference to data collected under the Home Mortgage Disclosure Act.

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