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Prior to the enactment of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), the Federal Reserve 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. Section 108 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA), codified at 15 U.S.C. 1639d, directs the Bureau to conduct 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 has also conducted a preliminary analysis of the number of lenders potentially impacted by implementation of section 108 of EGRRCPA, which relates to escrow requirements for loans made by certain creditors. The Bureau released the analysis which showed that a limited number of additional lenders would be exempt under section 108 of EGRRCPA once implemented by rule, in late summer 2019.