Higher-Priced Mortgage Loan Escrow Exemption (Regulation Z)

Updated 02/18/2021

The amendment would exempt from the HPML escrow requirement any loan made by an insured depository institution 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 in the preceding calendar year;
  3. During the preceding calendar year (or, if the application for the transaction was received before April 1 of the current calendar year, during either of the two preceding calendar years), the creditor made a consumer loan secured by a first lien on a dwelling (or property attached to a dwelling), that is located in an area that is either “rural” or “underserved”; and
  4. In general, the institution and its affiliates do not already maintain HPML escrow accounts. The only exceptions to this criterion are for escrow accounts established:
  • For first-lien HPMLs for which applications were received on or after April 1, 2010, to 120 days from effective date of this Final Rule (which is when the Rule is published in the Federal Register), or
  • After consummation as an accommodation to distressed consumers to help in avoiding default or foreclosure.

Members Can Download This Tool

Login to Download


Not Yet a Member?

Our members enjoy:

On-demand regulatory guidance hotline – by chat, phone and email – available from anywhere, on any device – 7 am - 6 pm, M-F, Central time 

Research time saved daily & weekly across forms, checklists, and trainings — for every regulation

Hours of form-building and branding of bank documents saved; in some cases, even the budget of additional staff

A sounding board for support and reassessment when institutional goals or the regulatory environment changes

Access to attorneys and compliance specialists for risk modelling and decision-making in advance of large business decisions

The knowledge that C/A was created and owned by 30 State Bankers Association to provide bank compliance services to their membership organizations

Find out how a personalized team of attorneys and compliance professionals helps build targeted compliance strategies throughout your institution when you take our Live Membership Demo.

Become a Member