On January 19th, the CFPB issued a Final Rule as a result of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) to potentially exempt more institutions from the HPML escrow requirements.
To be eligible for this expanded HPML escrow exemption, institutions must meet certain criteria. These criteria are based on asset size; loan origination volume; serving rural/underserved areas; and maintaining escrow accounts.
If you’re looking to get out of the HPML escrow requirements, this may be something you can take advantage of! First; however, you need to understand the different criteria and how they are met, including the timing, and when you also need to consider any affiliates.
The Rule will be in effect upon publication in the Federal Register.
We’ll have more information in the February edition of Banking on BCC next week. You can also join us on February 17th for our webinar, “The New HPML Escrow Exemption Final Rule” where we will break it all down in plain English!
Diane joined Banker’s Compliance Consulting with over 10 years of compliance experience and over 15 years of experience within the financial industry. Diane is a Certified Regulatory Compliance Manager (CRCM) and has a Bachelor’s Degree in Sociology with a concentration in Criminal Justice. She is a graduate of the Schools of Banking Compliance School and has participated in various other training opportunities throughout her career. Diane understands firsthand the struggles banks face in building and maintaining successful compliance programs. Her experience and common sense approach to consumer compliance is a great asset to our clients.
Diane and her husband have two kids who keep them busy. She enjoys running and other sports and is a big Bugs Bunny fan! She’s a bit crazy in that she does enjoy reading some of these regulations and she’s a “crazy cat lady!” Her cat tales are hilarious!