Because of a typographical error in last week's Bottom Line, we incorrectly reported that a creditor must have total assets of less than $2 million to qualify for the CFPB's escrow exemption for rural counties. A creditor qualifies for the exemption if it extends more than 50% of covered mortgage loans in rural or underserved counties, originates fewer than 500 covered transactions, had less than $2 billion in total assets at the end of the preceding year, and didn't maintain these kinds of escrow accounts except for HPMLs and as accommodations to distressed consumers.
IBAT has created a Texas map. Counties in red are rural. CFPB's list of rural counties may differ from this.