2023 Thresholds

With 2023 still feeling pretty new, do you ever start to think, “What did I forget?” Something that can slip through the cracks are the regulatory threshold changes that generally take effect on January 1^st each year. These thresholds are used to determine whether certain compliance requirements apply to your financial institution.

Here’s a quick list (not all-inclusive) of some common ones:

Regulation Z

• Loan Amount Exemption to determine if certain loans are subject to Regulation Z
• Points & Fees to determine High-Cost Mortgage status
• Loan Amount Exemption for appraisal requirements on Higher-Priced Mortgage Loans (HPMLs)
• Points & Fees to determine Qualified Mortgage (QM) status
• Asset Size for certain Small Creditor QMs
• Rate Spread to determine General QM status under the revised definition
• The asset size for the additional HPML escrow account exemption (resulting from the Economic Growth, Regulatory Relief, and Consumer Protection Act, aka EGRRCPA)

HMDA

• The asset-size threshold is one piece to determining if your financial institution is subject to HMDA.
• Also, don’t forget that the coverage threshold related to closed-end credit was recently reinstated to the original level of 25 (down from 100), which means more institutions will find themselves subject to HMDA in 2023.

CRA

• Asset-size thresholds for small, intermediate small, and large banks/savings institutions.

For more information on these threshold changes, refer to the January edition of our Banking on BCC Magazine.

Published
2022/12/30