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Home Compliance and Risk

Banking agencies announce annual threshold adjustments

December 15, 2025
Reading Time: 1 min read
CFPB issues decision on TILA preemption of state laws

The Consumer Financial Protection Bureau, Federal Reserve and the Office of the Comptroller of the Currency today announced that the 2026 threshold for higher-priced mortgage loans that are subject to special appraisal requirements will increase from $33,500 to $34,200.

The Dodd-Frank Act added special appraisal requirements for higher-priced mortgage loans to the Truth in Lending Act, or TILA. The new threshold amount will be effective Jan. 1, 2026, and is based on the 2.1% annual increase in the Consumer Price Index for Urban Wage Earners and Clerical Workers, known as CPI-W, as of June 1.

Separately, the CFPB and Fed announced the dollar thresholds used to determine whether certain consumer credit and lease transactions in 2026 are subject to certain protections under Regulation Z, which implements TILA, and Regulation M, which implements the Consumer Leasing Act.

Based on the 2.1% annual increase in the CPI-W, Regulation Z and Regulation M generally will apply to consumer credit transactions and consumer leases of $73,400 or less in 2026, the agencies said. However, private education loans and loans secured by real property, such as mortgages, are subject to Regulation Z regardless of the amount of the loan.

In addition, the CFPB announced the HOEPA and QM annual threshold adjustments in Regulation Z and increased from $15.50 to $16 the ceiling for what a consumer reporting agency may charge a consumer for disclosures under the Fair Credit Reporting Act.

Tags: CFPBConsumer lendingFDICFederal ReserveLendingOCC
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