Truth in Lending Act (Regulation Z) Adjustment to Asset-Size Exemption Threshold
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The brief below is a reading aid. The original source material and source link remain the governing reference.
Operational Brief
• The rule amends Regulation Z to implement changes made by the Dodd-Frank Act and updates asset-size thresholds for certain creditors. • The exemption for escrow accounts in higher-priced mortgage loans now applies to insured depository institutions and credit unions with assets of $10 billion or less, adjusted annually for inflation.
Why It Matters for Texas Credit Unions
The article does not explicitly mention Texas, TCUD, or any Texas-specific entities. The changes apply to all credit unions nationwide based on asset size, but do not have a specific impact on Texas CUs.
Who this most likely affects
Bounded site guidance: This item is most likely relevant for credit unions with meaningful mortgage, home-equity, or consumer-real-estate activity.
Why this fit: The source language points to lending, mortgage, or fair-lending activity that usually matters most where those programs are active.
This is site guidance, not a formal determination. CFPB Final Rules and the original source material remain the governing reference.
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This rule amends Regulation Z (Truth in Lending) to implement certain amendments to the Truth in Lending Act made by the Dodd-Frank Act. This rule amends the official commentary that interprets the requirements of the Bureau’s Regulation Z (Truth in Lending) to reflect changes in the asset-size thresholds for certain creditors to qualify for an exemption to the requirement to establish an escrow account for a higher-priced mortgage loan. These changes reflect updates to, 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). These amendments are based on the annual percentage change in the average of the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W).