CFPB Proposes Exemption from Establishing Escrow Accounts for Certain Mortgage Loans

The CFPB proposed amendments to Regulation Z (implementing the "Truth in Lending Act") to provide certain banks, savings institutions and credit unions an exemption from establishing escrow accounts for higher-priced mortgage loans ("HPMLs"). Under the proposal, the exemption would be available only as to an HPML secured by a "first lien on the principal dwelling of a consumer." An institution relying on the exemption must (i) have assets totaling not more than $10 billion, (ii) have provided no more than 1,000 loans secured by a first lien on a principal dwelling during the previous calendar year and (iii) meet a number of other conditions.

Comments on the proposal must be submitted within 60 days of its publication in the Federal Register.