On December 23, 2019, the CFPB announced the asset-size exemption threshold adjustment for creditors, including depository institutions, under Regulation Z, which implements the Truth in Lending Act. The asset-size threshold increased from $2.167 billion to $2.202 billion in 2020.
As a result, credit unions with assets of less than $2.202 billion (including assets of certain affiliates) as of December 31, 2019, are exempt — if other requirements of Regulation Z are met — from establishing escrow accounts for higher-priced mortgage loans in 2020. The adjustment also increases the asset-size threshold for credit unions making small-creditor portfolio and balloon-payment qualified mortgages under Regulation Z.
More information on the asset-size exemption is available in the Federal Register (opens new window).
You can find additional information on Truth in Lending Act on the NCUA’s Consumer Compliance Regulatory Resources page. If you have questions about this information, please contact the NCUA’s Office of Consumer Financial Protection with any questions at 703.518.1140 or by email at ComplianceMail@ncua.gov. Credit unions can also contact their NCUA regional office or their state supervisory authority.