New Reg C, Reg Z thresholds took effect Jan. 1

(Jan. 8, 2021) Credit unions and banks with assets of $48 million or less as of Dec. 31 are exempt from collecting data in 2021 under Regulation C (Home Mortgage Disclosure), the CFPB said last month in setting the regulation’s annual asset-size threshold.

The bureau said the $1 million upward adjustment in the threshold from last year was based on a 1.3% increase in the average of the CPI-W for the 12-month period ending in November 2020. As it usually does, the bureau noted that an institution’s exemption from collecting data in 2021 does not affect its responsibility to report data it was required to collect in 2020.

Also announced by the bureau: its adjustment to Regulation Z thresholds, stating that creditors with assets of less than $2.23 billion (including assets of certain affiliates) as of Dec. 31 are exempt, if other requirements of Regulation Z also are met, from establishing escrow accounts for higher-priced mortgage loans in 2021.

Regulation C notice

Regulation Z notice

FCRA notice