The Consumer Financial Protection Bureau (CFPB) finalized annual inflation-based amendments to certain Truth in Lending Act exemption thresholds applicable to covered mortgage lenders, as required by the Dodd-Frank Act.
In accordance with this requirement, the CFPB issued a final rule updating the official commentary interpreting Regulation Z to reflect changes in the asset-size thresholds for certain creditors to qualify for an exemption to the requirement to establish an escrow account for a higher-priced mortgage loan.
For certain first-lien higher-priced mortgage loans, the exemption threshold was increased to $2.785 billion from $2.717 billion. Therefore, creditors with assets of less than $2.785 billion (including assets of certain affiliates) as of Dec. 31, 2025, are exempt from establishing escrow accounts for higher-priced mortgage loans in 2026, provided other requirements of Regulation Z are also met.