Federal and Oregon Regulatory Update

January 6, 2020

The Consumer Financial Protection Bureau (“CFPB”) announced the asset-size exemption thresholds for 2020 for Regulation C and Regulation Z.  The Oregon Department of Consumer and Business Services has amended its rules for mortgage lenders and mortgage servicer licensees.  All updates discussed are effective January 1, 2020.




The Home Mortgage Disclosure Act (“HMDA”) requires lenders located in metropolitan areas to collect data about their housing-related lending activity.  Banks, savings associations, and credit unions are exempt from collecting data based on their assets.  The CFPB has indicated the asset-size exemption will increase from $46 million to $47 for the upcoming year.  Therefore, banks, savings associations, and credit unions with assets of $47 million or less as of December 31, 2019 are exempt from collecting HMDA data in 2020.




The Truth-in-Lending Act (“TILA”) requires lenders to establish an escrow account for a higher-priced mortgage loan.  The CFPB has amended Regulation Z’s Commentary to reflect a change in the asset size threshold for certain lenders to qualify for an exemption to the requirement to establish an escrow account for a higher-priced mortgage loan based on the annual percentage change in the average of the Consumer Price Index for Urban Wage Earners and Clerical Workers (“CPI-W”) for the 12-month period ending in November.  The exemption threshold is adjusted to increase from $2.167 billion to $2.202 billion.  Therefore, lenders with assets of $2.202 billion or less as of December 31, 2019 are exempt, if other requirements of Regulation Z are met, from establishing escrow accounts for higher-priced mortgage loans in 2020.


OREGON RULES 441-890-0075 and 441-850-0045


The Oregon Department of Consumer and Business Services has amended its rules related to displaying mortgage lender and mortgage servicer license information.


Mortgage lender and mortgage servicer licenses are required to display a copy of their license in the principal place of business.  If the licenses are issued or renewed through the NMLS on or after January 1, 2020, a licensee can meet the posting requirement by posting the form provided by the Department of Consumer and Business Services with current and valid NMLS licensing information. 


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Expert insights and regulatory updates on RegTech, compliance management, and fair lending.

Diane Jenkins

Director, National Mortgage Compliance Practice Group, AsurityDocs Of Counsel, Sandler Law Group

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