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

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

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.  The proposed amendments follow the Bureau’s May 2013 announcement that it intended to study potential adjustments to the terms “rural” and “underserved,” as well as its May 2014 request for comments regarding the small creditor loan origination threshold.  Comments on the proposed amendments are due on or before March 30, 2015, and the Bureau proposes that the amendments would become effective January 1, 2016.

Three of the CFPB’s major mortgage rules feature special provisions and exemptions for small creditors:  The escrow rule exempts certain small creditors from the requirement to establish escrow accounts for certain higher-priced mortgages; the ability-to-repay (ATR) rule includes three varieties of qualified mortgages—two permanent, one temporary—that are available only to small creditors; and the Home Ownership and Equity Protection Act (HOEPA) rule exempts small creditors from its prohibition on balloon payment features for certain high-cost mortgages.
Continue Reading CFPB proposes amendments to “small creditor,” “rural” exemptions

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

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

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