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Michigan Credit Union League

CFPB Publishes Small Entity Compliance Guide for the TILA Escrow Rule

The final TILA Escrow Rule was published on Jan. 10 with an additional proposed rule with request for public comment on April 12. The final rule, among other things, lengthens the time for which a mandatory escrow account established for a higher-priced mortgage loan must be maintained. The final rule takes effect on applications received on or after June 1. If you operate predominately in rural or underserved areas and meet certain asset size and other requirements, you may be eligible for an exemption from this rule for certain loans you hold in portfolio.

On April 18, the CFPB published its Small Entity Compliance Guide for the above TILA Escrow Rule. This is the second Small Entity Compliance Guide that the CFPB has published.  The bureau’s goal in publishing these guides is to provide a comprehensive summary of the rule in plain language and FAQ format. This guide will be helpful for credit unions that originate higher-priced mortgage loans secured by principal dwellings.  

You can sign up to receive notification of when these guides are published by entering your e-mail address in the upper-right section of the CFPB’s Regulations page under “Email updates.”

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