22-RA-03 Summary: 2022 Truth in Lending Act (Reg Z) Adjustment to Asset-Size Exemption Threshold

22-RA-03:  2022 Truth in Lending Act (Regulation Z) Adjustment to Asset-Size Exemption Threshold
February 2022

The Consumer Financial Protection Bureau (CFPB) has published annual adjustments for asset-size exemption thresholds under the Truth in Lending Act (TILA), as implemented by Regulation Z, which became effective on January 1, 2022.

Creditors with assets of less than $2.336 billion (including assets of certain affiliates) on December 31, 2021, are exempt from the requirement to establish escrow accounts for higher-priced mortgage loans in 2022 if other provisions of Regulation Z are also met. The adjustment to the asset-size exemption threshold for escrow accounts also increases the threshold for small creditor portfolio and balloon-payment qualified mortgages.

Creditors with assets of $10.473 billion or less (excluding assets of certain affiliates) as of December 31, 2021, are exempt from the Regulation Z higher-priced mortgage loan escrow requirement for any loan made by an insured depository institution or insured credit union and secured by a first-lien on the principal dwelling of a consumer.