Escrow Exemption Threshold for 2025

Adam Witmer
Regulatory Update, Regulation Z

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).

CFPB Takes Action to Stop Illegal Kickback Scheme to Steer Borrowers to Rocket Mortgage

Adam Witmer
Regulatory Update, RESPA

On December 23, 2024, the CFPB sued Rocked Homes to stop them from providing incentives to real estate brokers and agents in exchange for steering homebuyers to Rocket Mortgage, LLC for loans. The CFPB also sued Jason Mitchell, his real estate brokerage firm, JMG Holding Partners LLC, and several real estate brokerage companies for their role in the unlawful scheme. 

CFPB Sues Three of the Largest Banks and Zelle for Failure to Protect Consumers from Fraud

Adam Witmer
Regulatory Update

On December 20, 2024, the CFPB sued the operator of Zelle and three of the nation’s largest banks, Bank of America, JPMorgan Chase, and Wells Fargo, for failing to protect consumers from widespread fraud on America’s most widely available peer-to-peer payment network. According to the CFPB, Early Warning Services, which operates Zelle, along with its owner banks rushed the network to market to compete against growing payment apps such as Venmo and CashApp, without implementing effective consumer safeguards.

Treasury Disrupts North Korean Money Laundering Network

Adam Witmer
Regulatory Update, BSA

On December 17, 2024, the OFAC sanctioned two individuals and one entity involved in a network that launders millions of dollars of illicit funds generated by the Democratic People’s Republic of Korea (DPRK) information technology (IT) workers and cybercrime to support the DPRK Government. The sanctions are part of OFAC’s ongoing efforts to disrupt the DPRK’s money laundering operations, which finance the regime’s unlawful weapons of mass destruction (WMD) and ballistic missile programs. 

FinCEN Warns of Fraud Schemes Exploiting Its Name and Authority

Adam Witmer
Regulatory Update, BSA

On December 18, 2024, FinCEN issued an alert to raise awareness of fraud schemes abusing FinCEN’s name, insignia, and authorities for financial gain. These FinCEN-specific fraud schemes include scams that exploit beneficial ownership information reporting; misuse FinCEN’s Money Services Business Registration tool; or involve the impersonation of, or misrepresent affiliation with, FinCEN and its employees.

Load More