2026 Threshold Adjustments

Michael Christians • January 7, 2026

Each year, the Consumer Financial Protection Bureau and other federal government agencies are required to adjust a number of regulatory thresholds to account for inflation. Most adjustments are based on the annual percentage change in the Consumer Price Index. The following thresholds were effective January 1, 2026.


Fannie Mae/Freddie Mac Conforming Loan Limits

$832,750 ($1,249,125 for high-cost areas)


Home Mortgage Disclosure Act Institutional Coverage Test

A financial institution that meets the following four-part test is subject to HMDA:

  • Assets in excess of $59 million as of 12/31/2025,
  • Home or branch office in a Metropolitan Statistical Area (MSA),
  • Originated at least one home purchase or refinance transaction in the preceding calendar year, and
  • Federally insured or regulated.


Qualified Mortgage Pricing Test

First Lien Loans

The APR charged in connection with the transaction does not exceed the current value of the APOR index by more than:

  • 2.25% for loans greater than or equal to $137,958
  • 3.50% for loans greater than or equal to $82,775 but less than $137,958
  • 6.50% for loans less than $82,775


Subordinate Lien Loans

The APR charged in connection with the transaction does not exceed the current value of the APOR index by more than:

  • 3.50% for loans greater than or equal to $82,775
  • 6.50% for loans less than $82,775


Qualified Mortgage Points and Fees Test

  • Loans greater than $137,958 - 3% of the loan amount
  • Loans between $82,775 and $137,958 - $4,139
  • Loans between $27,592 and $82,775 - 5% of the loan amount
  • Loans between $17,245 and $27,592 - $1,380
  • Loans less than $17,245 - 8% of the loan amount


Small Creditor Definition

A financial institution that meets the following two-part test is considered a small creditor:

  • During the preceding calendar year, the financial institution and its affiliates together originated 2,000 or fewer covered transactions secured by a first lien, and
  • At the end of the preceding calendar year, the financial institution and its affiliates together had total assets of less than $2.785 billion.


Higher Priced Mortgage Loan Appraisal Requirement

Generally, in connection with a higher priced mortgage loan, a financial institution must obtain a written appraisal of the subject property. However, if one of the following exceptions applies, an alternative method of valuation may be used:

  • The higher priced mortgage loan also meets the definition of a qualified mortgage,
  • An extension of credit equal to or less than $34,200,
  • A transaction secured by a mobile home, boat, or trailer,
  • A construction loan,
  • A bridge loan with a term of 12 months or less, or
  • A reverse mortgage.


High-Cost Mortgage Points and Fees Test

A loan is considered high cost if the points and fees charged in connection with the transaction exceed:

  • 5% of the loan amount for loans of $27,592 or greater
  • For loans of less than $27,592, the lesser of -
  • 8% of the loan amount, or
  • $1,380


Credit Card Minimum Interest Charge

A card issuer is required to disclose any minimum interest charge exceeding $1.00 that could be imposed during a billing cycle.


Regulation Z Exemption

An extension of credit in excess of $73,400 is exempt from Regulation Z unless it is:

  • Secured by any real property or by personal property used by the consumer as his/her principal dwelling, or
  • A private education loan.


Regulation M Exemption

A consumer lease with a total contractual obligation in excess of $73,400 is exempt from Regulation M. 


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