HPML Escrow Exemption 2021 Final Rule Summary
Updated 02/18/2021
This tool summarizes the CFPB’s Final Rule amending HPML provisions under Regulation Z by providing a new exemption from the requirement to establish an escrow account. The following are the key takeaways of the exemption:
- The exemption applies only to insured institutions.
- The exemption has an asset size threshold of $10 billion or less and a loan volume threshold of 1,000 or less originations.
- An institution must also meet certain existing criteria to qualify for the new exemption. The first criterion deals with serving rural or underserved areas. The second criterion known as the non-escrow prerequisite states that the institution must not have established escrow accounts subject to two exclusions.
- The exclusion to the non-escrow prerequisite that deals with escrow accounts established on or after April 1, 2010 and before May 1, 2016 has been amended with a new end-date as 120 days after this rule is published in the Federal Register.
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