The CFPB has finalized two routine but consequential updates to federal mortgage rules, increasing asset-size thresholds tied to Home Mortgage Disclosure Act reporting and escrow requirements for higher-priced mortgage loans.
In one final rule, the CFPB raised the HMDA asset-size exemption threshold from $58 million to $59 million for 2026. As a result, banks, savings associations and credit unions with assets of $59 million or less as of Dec. 31, 2025, will be exempt from collecting and reporting HMDA data next year. The adjustment reflected a 2.5% increase in the Consumer Price Index for Urban Wage Earners and Clerical Workers and is required annually by statute. The Bureau emphasized the change is technical and does not alter fair-lending standards or prior reporting obligations.
In a separate filing, the CFPB also updated asset-size thresholds under Regulation Z governing escrow requirements for higher-priced mortgage loans. For 2026, the small-creditor exemption threshold for lenders and their affiliates that regularly extend first-lien covered transactions increased to $2.785 billion. In addition, the exemption threshold for insured depository institutions and insured credit unions rose to $12.485 billion, allowing qualifying institutions to avoid mandatory escrow accounts for certain loans if other criteria are met.
These escrow thresholds are especially significant for community-focused and rural lenders, as they also affect eligibility for portfolio qualified mortgages and balloon-payment qualified mortgages.
The CFPB noted that both rules were finalized without notice-and-comment because the updates are nondiscretionary and purely inflation-driven. While modest in size, the adjustments are expected to provide compliance relief for smaller institutions in 2026, particularly credit unions operating near the reporting and escrow thresholds, while keeping the underlying consumer-protection framework intact.
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