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Prior to the enactment of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), the Board of Governors of the Federal Reserve System (Board) issued a rule requiring the establishment of escrow accounts for payment of property taxes and insurance payments for certain "higher-priced mortgage loans,” a category which the Board defined to capture what it deemed to be subprime loans.  Pursuant to the Dodd-Frank Act, the Bureau in 2013 issued a rule creating an exemption from the escrow requirement for creditors with under $2 billion in assets and meeting other criteria. Pursuant to section 108 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA), codified at 15 U.S.C. 1639d, the Bureau conducted a rulemaking to exempt from the escrow requirement loans made by certain creditors with assets of $10 billion or less and meeting other criteria.  In anticipation of future rulemaking activity, the Bureau conducted a preliminary analysis of the number of lenders potentially impacted by implementation of section 108 of EGRRCPA.  The Bureau released the analysis in late summer 2019 and it showed that a limited number of additional lenders would be exempt under section 108 of EGRRCPA once implemented by rule.  The Bureau issued a Notice of Proposed Rulemaking in July 2020 and issued a final rule in early 2021.