CFPB Issues Final Rule on HPML Escrow Exemption

On 1/19/2021, the CFPB issued a final rule that exempts certain insured depository institutions and insured credit unions from the requirement to establish escrow accounts for certain higher-priced mortgage loans (HPMLs). This final rule implements a requirement of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA).

According to the CFPB’s release, the final rule takes effect upon publication in the Federal Register and exempts from the HPML escrow requirement any loan made by an insured depository institution or insured credit union 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 during the preceding calendar year; and (3) certain of the existing HPML escrow exemption criteria are met.

The 68-page final rule can be found here.

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