Protection Act ( 12 U.S.C. 5371(b)(5) ) is amended to read as follows: (C) any bank holding company or savings and loan holding company that is subject to the application of the Small Bank Holding Company Policy Statement on Assessment of Financial and Managerial Factors of the Board of Governors (12 CFR part 225—appendix C). . 920. Community financial institution mortgage relief (a) Exemption from escrow requirements for loans held by smaller creditors Section 129D of the Truth in Lending Act ( 15 U.S.C. 1639d ) is amended— (1) by adding at the end the following: (k) Safe harbor for loans held by smaller creditors (1) In general A creditor shall not be in violation of subsection (a) with respect to a loan if— (A) the creditor has consolidated assets of $10,000,000,000 or less