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ARTICLE · 07 JANUARY 2021

CFPB Adjusts HMDA And TILA Asset Exemption Thresholds

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Banks, savings associations, and credit unions are not subject to HMDA for a calendar year if their assets as of December 31, of the prior calendar year did not exceed an asset threshold.

United StatesFinance and Banking
Richard J. Andreano, Jr.
Richard J. Andreano, Jr.
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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) requirement to maintain an escrow account for a higher-priced mortgage loan.

Banks, savings associations, and credit unions are not subject to HMDA for a calendar year if their assets as of December 31, of the prior calendar year did not exceed an asset threshold. The asset threshold is subject to annual adjustment based on inflation. The asset threshold for calendar year 2020 HMDA data collection and reporting was $47 million. The final rule increases the asset threshold for calendar year 2021 HMDA data collection and reporting to $48 million. As a result, banks, savings associations, and credit unions with assets of $48 million or less as of December 31, 2020, are exempt from collecting and reporting HMDA data for 2021 activity.

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