Exemption Thresholds Adjusted For Some Regulations

A number of compliance-related regulations have threshold amounts below which institutions are exempt from compliance requirements. The applicable regulatory agency is often required to adjust the threshold levels annually by the percentage increase in the Consumer Price Index.

HMDA/Reg. C. The CFPB did not adjust the asset-size exemption threshold in 2016 for banks, savings associations and credit unions under Regulation C, which implements the Home Mortgage Disclosure Act (HMDA). The asset-size exemption will remain at $44 million. Institutions with assets of $44 million or less as of December 31, 2015 are exempt from collecting HMDA data in 2016.

TILA/Reg. Z. Effective January 1, 2016, the CFPB adjusted the asset-size exemption threshold under Regulation Z, which implements the Truth in Lending Act. The asset-size threshold for certain creditors to qualify for an exemption to the requirements to establish an escrow account for a higher-priced mortgage loan is