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CFPB raises HMDA, Reg Z thresholds for 2024
The CFPB has finalized annual changes to the asset-size exemption thresholds under the Home Mortgage Disclosure Act (HMDA) and Regulation Z for 2024, based on the 4.1 percent increase 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 2023.
Under HMDA, the bureau increased the exemption threshold to $56 million from $54 million. Credit unions with assets of $56 million or less as of Dec. 31, 2023, are exempt from collecting data in 2024. However, an institution's exemption from collecting data in 2024 does not affect its responsibility to report data it was required to collect in 2023.
The changes to Regulation Z exempt creditors with assets of less than $2.640 billion as of Dec. 31, 2023, and that meet certain other requirements from establishing escrow accounts for higher-priced mortgage loans in 2024. This asset limit will also apply during a grace period in 2025, in certain circumstances, with respect to transactions with applications received before April 1, 2025.