Reg Alert details CFPB thresholds for Regs C, Z, V

(Feb. 5, 2021) A regulatory alert focusing on 2021 threshold adjustments published by CFPB for Regulations C, Z and V was issued this week by NCUA, noting that all three were effective Jan. 1.

The alert notes that, in January, the bureau published annual adjustments for exemption thresholds under the Home Mortgage Disclosure Act (Regulation C) and the Truth in Lending Act (Regulation Z). The asset-size thresholds, the alert points out, exempt some credit unions from data collection under Regulation C and from escrow account requirements for higher-priced mortgage loans and specific qualified mortgages under Regulation Z.

The CFPB published an annual adjustment to the maximum amount consumer reporting agencies may charge consumers for making a file disclosure to a consumer under Regulation V, the alert also notes

More specifically the alert states:

  • The Reg C exemption threshold increased to $48 million (meaning credit unions with $48 million or less in assets as of Dec. 31, 2020, are exempt from collecting HMDA data this year);
  • The Reg Z escrow and small creditor qualified mortgages (QMs) asset-size exemption threshold increased to $2.23 billion (meaning lenders with assets of less than $2.23 billion at the end of last year are expect if other provisions of Reg Z are also met). The limit also applies during a grace period, in certain circumstances, with respect to transactions with applications received before April 1, 2022.
  • The ceiling on the allowable amount a consumer reporting agency may charge for a consumer report in 2021 increased to $13. “The ceiling does not affect the amount a credit union may charge its members or potential members, directly or indirectly, for obtaining a credit report in the normal course of business,” NCUA noted.

CFPB Publishes 2021 Threshold Adjustments Under Regulation C, Regulation Z and Regulation V (NCUA Regulatory Alert 21-RA-02)