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!