Comments Due to NAFCU: CFPB - Higher-Priced Mortgage Loan Escrow Exemption
NAFCU would like to highlight the following:
- The proposal would create a new exemption for insured credit unions from the requirement to establish escrow accounts for a loan secured by a first lien on the principal dwelling of a consumer if: (1) the institution has assets of $10 billion or less; (2) the institution and its affiliates originated 1,000 or fewer loans secured by a first lien on a principal dwelling during the preceding calendar year; and (3) certain of the existing higher-priced mortgage loans (HPML) escrow exemption criteria are met.
Comments due to NAFCU: September 18, 2020
Comments due to CFPB: September 21, 2020
NAFCU will send comments on behalf of its members to the CFPB by their deadline (September 18, 2020).