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Affiliate (HPML Escrow Rule)

Updated 2024-07-29

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For the purposes of the HPML Escrow Exemptions under Regulation Z, an affiliate is defined as any company that controls, is controlled by, or is under common control with another company.

This definition is set forth in the Bank Holding Company Act of 1956 (12 U.S.C. 1841 et seq.).

The activities and assets of affiliates are often aggregated when determining eligibility for exemptions from the HPML Escrow Rule, particularly for the small creditor exemption.

Citation: 12 CFR § 1026.32(b)(5)

Source material

  • 201603_cfpb_tila hpml escrow_compliance guide

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