The CFPB has posted its 2017 final lists of Rural and Rural or Underserved Counties on its website.  The CFPB has previously posted lists of such counties for calendar years 2011-2016.

The lists are relevant to exemptions in several CFPB mortgage rules, including the CFPB’s rule requiring creditors to establish escrow accounts for certain first-lien higher-priced mortgage loans.… Continue Reading

The CFPB has announced annual adjustments to two asset-size exemption thresholds.  First, the CFPB is making no change to the asset-size exemption threshold under HMDA/Regulation C which is currently set at $44 million.  Banks, savings associations, and credit unions with assets at or below $44 million as of December 31, 2015 will continue to be exempt from collecting HMDA data in 2016.… Continue Reading

On January 29, the CFPB proposed amendments to the portions of Regulation Z governing mortgages made by small creditors.  In the same notice, the CFPB also proposed amendments to Regulation Z’s definition of the term “rural,” which controls certain special permissions for small creditors operating predominately in areas that satisfy the definition. … Continue Reading

The CFPB has posted its 2015 final lists of Rural and Rural or Underserved Counties on its website.  The CFPB has previously posted lists of such counties for calendar years 2011-2014.

The lists are relevant to exemptions in several CFPB mortgage rules, including the CFPB’s rule requiring creditors to establish escrow accounts for certain first-lien higher-priced mortgage loans.  … Continue Reading

The CFPB has posted on its website a list of rural and underserved counties for calendar year 2011.  The CFPB had already posted lists of such counties for calendar years 2012 and 2013. 

As initially adopted, the CFPB’s final rule requiring creditors to establish escrow accounts for certain first-lien higher-priced mortgage loans contained an exemption for certain small creditors that operated predominantly in “rural” or “underserved” counties in the preceding calendar year.… Continue Reading

The CFPB has released a final list of “rural” or “underserved” counties for use in 2014.  The CFPB has indicated that  creditors may rely on this list as a safe harbor to determine whether a county is “rural” or “underserved” for loans made during a given calendar year.  (In
May 2013, the CFPB released the list for loans made from June 1, 2013, through
December 31, 2013).… Continue Reading

The CFPB has proposed amendments to its final mortgage escrow account rule dealing with the establishment of mandatory escrow accounts on higher-priced mortgage loans (HPML).  According to the proposal’s supplementary information, the proposal is the “first publication of additional guidance and updates regarding the Title XIV Final Rules.”  It further states that because the final rule is effective June 1, 2013, the CFPB gave priority to issuing the proposal. … Continue Reading