CFPB Issues Rule On Escrow Exemptions For High-Priced Mortgage Loans

Jul 02, 2020

The Consumer Financial Protection Bureau (CFPB) issued a notice of proposed rulemaking (NPRM) that would amend Regulation Z to provide a new exemption available to certain insured depository institutions and insured credit unions from the requirement to establish escrow accounts for certain higher-priced mortgage loans (HPMLs). In issuing the NPRM, the CFPB commenced its last mandatory rulemaking to implement the Economic Growth, Regulatory Relief and Consumer Protection Act (EGRRCPA).

HPMLs are closed-end consumer credit transactions secured by the consumer’s principal dwelling with an annual percentage rate that exceeds the average prime offer rate for a comparable transaction by specific amounts as of the date the interest rate is set. For the most part, first-lien HPMLs must have escrow accounts.

The proposed amendment would exempt from the Regulation Z HPML escrow requirement 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 if (1) the institution has assets of $10 billion or less; (2) the institution and its affiliates originated 1,000 or fewer loans secured by a first lien on a principal dwelling during the preceding calendar year; and (3) certain other criteria are met.

The proposed amendment would further the goals EGRRCPA by reducing costs associated with escrow requirements.

About the author

NationalMortgageProfessional.com

Link copied

Published

Jul 02, 2020

Non-QM

Home Equity Lending Could Overtake Non-QM In 2027

Lenders report rising second-lien production as homeowners protect low first-mortgage rates

Home equity lending is growing fast, and industry executives expect it to surpass Non-QM in origination volume as soon as 2027."I think equity originations are expected to surpass NonQM originations in 2027," said Tom Davis, chief sales officer at Deephaven Mortgage.The grow...

Analysis and Data

Home Contract Signings Hit Record October Low, Falling 17%

Realtor.com reports a sharp decline in purchase activity as higher rates erode borrowing power

Home contract signings fell 17% year over year in October, reaching their lowest level for the month on record, as higher mortgage rates continued to squeeze buyers out of the purchase market, according to Realtor.com's latest housing report.The annual decline was the steepe...

Jan

Uncasville, CT

More from

Regulation and Compliance

Midterms Loom With Mortgage Policy Changes Already In Motion

As voters head to the polls Tuesday, Washington is weighing changes to refinancing costs, loan pricing, and lending regulations

Regulation and Compliance

Nov 02, 2026

UAD 3.6 Deadline Is Monday. Are Brokers Ready?

Wholesale lenders have adopted different rules for appraisal transfers, loan product changes, and reporting formats, adding complications for brokers and appraisers ahead of the Nov. 2 mandate

Regulation and Compliance

Oct 27, 2026

Friday Harbor Expands AI Appraisal Reviews As UAD 3.6 Deadline Nears

The new capability adds more than 350 automated checks as lenders prepare for the November 2 mandate

Tech

Oct 27, 2026

The Hidden Cost Of Appraisal Uncertainty

As home equity lending grows, lenders need a better way to resolve conflicting property evidence before it creates costly setbacks

Regulation and Compliance

Oct 25, 2026

Trump Targets Mortgage Insurance, Refi Costs In Sweeping Housing Order

The executive order calls for automatic mortgage insurance cancellation, expanded title insurance alternatives, and cheaper refinances, potentially changing how lenders and servicers handle borrower costs

Regulation and Compliance

Oct 23, 2026