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Effective Date: Truth in Lending Act (Regulation Z) Adjustment to Asset-Size Exemption Threshold- requirement to establish an escrow account for HPML

AGENCY: Consumer Financial Protection Bureau.

ACTION: Final rule; official interpretation.

SUMMARY: For certain first-lien higher-priced mortgage loans, the exemption threshold is adjusted to increase to $2.785 billion from $2.717 billion. Therefore, creditors with assets of less than $2.785 billion (including assets of certain affiliates) as of Dec. 31, 2025, are exempt, if other requirements of Regulation Z also are met, from establishing escrow accounts for higher-priced mortgage loans in 2026. This asset limit will also apply during a grace period, in certain circumstances, with respect to transactions with applications received before April 1 of 2027. For certain insured depository institutions and insured credit unions meeting certain conditions, including an asset size exemption threshold, the exemption threshold is adjusted to increase to $12.485 billion from $12.179 billion. Therefore, insured depository institutions and insured credit unions that during calendar year 2025 had assets of $12.485 billion or less on December 31, 2025, will meet the asset-size exemption threshold for purposes of any loan consummated in 2026 and for purposes of any loan secured by a first lien on a principal dwelling of a consumer consummated in 2027 for which the application was received before April 1, 2027. These adjustments are based on the 2.5 percent increase in the average of the CPI-W for the 12-month period ending in November 2025.

DATES: Effective date: This rule is effective on January 7, 2026.

https://www.federalregister.gov/documents/2026/01/07/2026-00085/truth-in-lending-act-regulation-z-adjustment-to-asset-size-exemption-threshold

  • January 7, 2026
  • Time: All Day