As of which date must a credit union not have been required to escrow under any law to qualify for the small lender exception?

To qualify for the small lender exception, a credit union must not have been required to escrow under any law as of July 6, 2012. This date is significant because it establishes a specific cut-off point after which the small lender exception applies, allowing eligible lenders to avoid the obligation to maintain escrow accounts for certain loans. The importance of this rule lies in its intent to alleviate regulatory burdens on smaller lenders, recognizing that they may have less capacity to manage such requirements compared to larger financial institutions.

The date July 6, 2012, is directly tied to amendments and regulations that govern escrow requirements for residential mortgage loans, often relating to the Housing and Urban Development (HUD) guidelines, which distinguish larger entities from smaller community-based lenders like credit unions. This specific timing reflects necessary legislative changes aimed at protecting small lenders while minimizing operational complexities when compared to larger competitors.