On December 23, 2024, the CFPB announced the annual adjustment to the asset size threshold for certain creditors to qualify for an exemption to the requirement to establish an escrow account for a higher-priced mortgage loan under Regulation Z. These changes reflect updates to the exemption from TILA’s escrow requirement of creditors that, together with affiliates that regularly extended covered transactions secured by first liens, had total assets of less than $2 billion (adjusted annually for inflation) and the exemption the Bureau added, by implementing section 108 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA), for certain insured depository institutions and insured credit unions with assets of $10 billion or less (adjusted annually for inflation).
For 2025, the exemption threshold for creditors and their affiliates that regularly extended covered transactions secured by first liens is adjusted to $2.717 billion from $2.640 billion while for certain insured depository institutions and insured credit unions with assets of $10 billion or less (adjusted annually for inflation), the exemption threshold is adjusted to $12.179 billion from $11.835 billion. The adjustments were based on the 2.9 percent increase in the average of the CPI-W for the 12-month period ending in November 2024.
The final rule can be found here.