In a letter filed with CFPB, WBA stated general support to implement EGRRCPA section 108 to exempt from Regulation Z’s HPML escrow rules any loan made by a financial institution that is secured by a first lien on the principal dwelling of a consumer if the institution: (1) has assets of $10 billion or less; (2) together with its affiliates originated 1,000 or fewer loans secured by a first lien on a principal dwelling during the preceding calendar year; and (3) meets certain existing HPML escrow exemptions criteria. The new exemption is in addition to existing HPML escrow exemptions. 

To help alleviate the potential that an institution inadvertently makes itself ineligible for the new exemption, the proposal would also modify a May 1, 2016 date within the current HPML escrow exemption requirements to a new end date that will be approximately 90 days after the effective date of the forthcoming final rule.  

While WBA stated general support, WBA recommended the 90-day prerequisite be extended to no less than 120 days as additional time is needed for financial institutions to identify and adapt to the changes made by the proposed rule. The letter may be viewed below: