2022 Regulatory Threshold Changes

With 2022 still feeling pretty new, do you ever start to think, “What did I forget”?  Something that can slip through the cracks are the regulatory threshold changes that generally take effect on January 1st each year.  These thresholds are used to determine whether certain compliance requirements apply to your financial institution.

Here’s a quick list (not all-inclusive) of some common ones:

Regulation Z

  • Loan Amount Exemption to determine if certain loans are subject to Regulation Z
  • Points & Fees to determine High-Cost Mortgage status
  • Loan Amount Exemption for appraisal requirements on Higher-Priced Mortgage Loans (HPMLs)
  • Points & Fees to determine Qualified Mortgage (QM) status
  • Asset Size for certain Small Creditor QMs
  • Rate Spread to determine General QM status under the revised definition
  • The asset size for the additional HPML escrow account exemption (resulting from the Economic Growth, Regulatory Relief, and Consumer Protection Act aka EGRRCPA)

HMDA

  • The asset-size threshold is one piece to determining if your financial institution is subject to HMDA.
  • Also beginning in 2022, the loan volume threshold related to open-end credit has changed and certain open-end credit reporters may qualify for small-filer status.

CRA

  • Asset-size thresholds for small, intermediate small and large banks/savings institutions.

For more information on these threshold changes, refer to the January edition of our Banking on BCC Magazine.

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Regulatory Threshold Changes

Published
2021/12/30

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