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01.03.2019
Bureau Raises Thresholds for HMDA, Regulation Z
The Bureau of Consumer Financial Protection has finalized changes to asset-size exemption thresholds under the Home Mortgage Disclosure Act (HMDA) and Regulation Z, and has also raised the ceiling for allowable charges under the Fair Credit Reporting Act (FCRA).

Under HMDA, the bureau increased the exemption threshold to $46 million from $45 million. Credit unions with assets of $46 million or less as of Dec. 31, 2018, are exempt from collecting data in 2019. However, an institution's exemption from collecting data in 2019 does not affect its responsibility to report data it was required to collect in 2018.

The changes to Regulation Z exempt creditors with assets of less than $2.167 billion as of Dec. 31, 2018, and that meet certain other requirements from establishing escrow accounts for higher-priced mortgage loans in 2019.

The adjustment to the escrow account threshold will also increase a similar threshold for small-creditor portfolio and balloon-payment qualified mortgages. Balloon-payment qualified mortgages that satisfy all applicable criteria, including being made by creditors that have total assets below the threshold, are also excepted from the prohibition on balloon payments for high-cost mortgages.

The bureau has also raised the FCRA's ceiling on what consumer reporting agencies (CRAs) are allowed to charge consumers who request their information file after their guaranteed free file disclosure in a 12-month period. The maximum allowable charge for 2019 is now $12.50.

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