source:
  type: regulation
  id: eo-14393-mortgage-credit
  authority: Executive Order 14393 — Promoting Access to Mortgage Credit
  status: directive-watch
  description: 'Executive Order 14393 (signed Mar 13, 2026; 91 FR 13203, Mar 18, 2026). A DIRECTIVE, not a rule: directs the CFPB and banking agencies to CONSIDER tailoring Reg Z (ATR/QM, TILA/RESPA/TRID), Reg C/HMDA thresholds, and capital rules for community/smaller banks. Nothing is in force; downstream rulemakings expected late 2026/2027. Tracked here for lead-time readiness.'
obligations:
- id: eo-14393-regulation-z-tailoring
  canonical_id: eo-14393-regulation-z-tailoring
  section: 'EO 14393 — WATCH: directs CFPB to consider tailoring Reg Z (ATR/QM, TILA/RESPA/TRID) for smaller banks'
  description: WATCH (directive, not a rule). The EO directs the CFPB to consider proposing amendments to Regulation Z tailoring ATR/QM and TILA/RESPA/TRID requirements for smaller banks.
  type: proposed
  audit_question: Is [LENDER] tracking the EO 14393 directive on Reg Z tailoring (ATR/QM, TILA/RESPA/TRID) so it can respond when a proposed rule appears?
  workflow_phase: origination
  owner_role: cco
  secondary_owner_role: cco
  cadence: monitor
  consequence: Acting on stale or un-finalized requirements creates legal exposure; failing to track them forfeits lead time.
  tags:
  - eo-14393
  - watch
  - reg-z
  - atr-qm
  - trid
  - directive
  - monitor
  primary_source:
    tier: 1
    authority: Executive Order 14393 — Promoting Access to Mortgage Credit (91 FR 13203, Mar 18, 2026)
    source_class: executive-order
    source_url: https://www.federalregister.gov/documents/2026/03/18/2026-05384/promoting-access-to-mortgage-credit
    snapshot_id: cb44bb165ce54715
    fetched_at: '2026-06-08T00:00:00Z'
    content_hash: sha256:placeholder-snapshot-content-hash-from-source-json
    paragraph_quote: 'proposing amendments to Regulation Z that tailor the following requirements for smaller banks: ATR and QM requirements (including potentially a broader QM safe harbor for portfolio loans) and the requirements of the Truth in Lending Act, Public Law 90-321 (TILA), Real Estate Settlement Procedure Act, Public Law 93-533 (RESPA), and TILA-RESPA Integrated Disclosure (TRID) rules;'
    drafter_attestation: Verbatim from EO 14393 snapshot. Directive to consider Reg Z amendments — not yet a rule.
  program_review: Does the program monitor for the Reg Z rulemaking this EO directs, so a comment/readiness response is ready if it proposes?
  file_review: 'WATCH — no in-force file duty. Readiness only: which ATR/QM/TRID controls would change if the directed amendments are proposed.'
  judgment: false
- id: eo-14393-regulation-c-hmda-tailoring
  canonical_id: eo-14393-regulation-c-hmda-tailoring
  section: 'EO 14393 — WATCH: directs CFPB to consider raising the HMDA (Reg C) asset-threshold exemption'
  description: WATCH (directive, not a rule). The EO directs the CFPB to consider proposing amendments to Regulation C raising the asset threshold for exemption from HMDA collection/reporting for smaller banks and excluding inquiries.
  type: proposed
  audit_question: Is [LENDER] tracking the EO 14393 directive on Reg C / HMDA threshold and scope changes?
  workflow_phase: origination
  owner_role: cco
  secondary_owner_role: cco
  cadence: monitor
  consequence: Acting on stale or un-finalized requirements creates legal exposure; failing to track them forfeits lead time.
  tags:
  - eo-14393
  - watch
  - reg-c
  - hmda
  - directive
  - monitor
  primary_source:
    tier: 1
    authority: Executive Order 14393 — Promoting Access to Mortgage Credit (91 FR 13203, Mar 18, 2026)
    source_class: executive-order
    source_url: https://www.federalregister.gov/documents/2026/03/18/2026-05384/promoting-access-to-mortgage-credit
    snapshot_id: cb44bb165ce54715
    fetched_at: '2026-06-08T00:00:00Z'
    content_hash: sha256:placeholder-snapshot-content-hash-from-source-json
    paragraph_quote: proposing amendments to Regulation C to raise the asset threshold for exemption from HMDA data collection and reporting requirements for smaller banks, to exclude inquiries from the scope of HMDA
    drafter_attestation: Verbatim from EO 14393 snapshot. Directive to consider Reg C amendments — not yet a rule.
  program_review: Does the program monitor for the HMDA (Reg C) rulemaking this EO directs?
  file_review: 'WATCH — no in-force file duty. Readiness only: HMDA reporting scope if the directed amendments are proposed.'
  judgment: false
