The threshold used to determine small creditor status under Regulation Z will be $2.052 billion in 2016. This is down from $2.060 billion in 2015. This threshold comes into play for the Ability to 
Repay/Qualified Mortgage rules under §1026.43 and HPML escrow accounts under §1026.35(b)(2)(iii)(C).
Published
2015/12/24
Amy Kudlacek
Amy brings many years of banking and compliance experience to Banker’s Compliance Consulting. She has worked for both large and small financial institutions and spent time working in every area of a bank. She started out as a teller in college and eventually became a branch manager. Her love, however, was always compliance. Amy began her career with Banker’s Compliance Consulting in 2000. Her knowledge and experiences have allowed her to develop a well-rounded and practical approach to regulatory compliance. Amy is CRCM certified, has a Bachelors Degree in Business Administration and is a graduate of the ABA Compliance School. Amy & her husband have two children at home and stay busy following their activities. They spend a lot of time in the bleachers!