Compliance Journal January 2025
Special Focus 2025 Adjusted Regulatory Thresholds and Limits As we enter the new year, regulatory agencies have announced adjustments to several loan, lease, and retirement account related thresholds and limits. The following is a listing of the adjustments effective January 1, 2025, including a link to pull each publication for reference. Regulation Z, TILA •
The exemption threshold for Regulation Z (Truth in Lending Act) will increase to $71,900, up from $69,500. https://www.govinfo.gov/content/pkg/FR-2024-10-15/pdf/2024-23275.pdf
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The exemption threshold under Regulation Z for HPML appraisals will increase to $33,500, up from $32,400. https://www.govinfo.gov/content/pkg/FR-2024-10-15/pdf/2024-23277.pdf
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The asset-size threshold under Regulation Z which exempts creditors from the requirement to establish an escrow account for HPMLs will be: o For creditors and their affiliates that regularly extended covered transactions secured by first liens, the asset-size threshold is adjusted to $2.717 billion, up from $2.640 billion; and o The exemption threshold for certain insured depository institutions with assets of $10 billion or less is adjusted to $12.179 billion, up from $11.835 billion. https://www.govinfo.gov/content/pkg/FR-2024-12-23/pdf/2024-30653.pdf
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The dollar amount thresholds under Regulation Z for HOEPA and QM-related loans have been adjusted as follows: o For HOEPA loans, the adjusted total loan amount threshold for high-cost mortgages will be $26,968. o The adjusted points-and-fees dollar trigger for high-cost mortgages will be $1,348. o For QMs under the General QM loan definition in § 1026.43(e)(2), the thresholds for the spread between the annual percentage rate (APR) and the average prime offer rate (APOR) will be: • 2.25 or more percentage points for a first-lien covered transaction with a loan amount greater than or equal to $134,841; • 3.5 or more percentage points for a first-lien covered transaction with a loan amount greater than or equal to $80,905 but less than $134,841; • 6.5 or more percentage points for a first-lien covered transaction with a loan amount less than $80,905; • 6.5 or more percentage points for a first-lien covered transaction secured by a manufactured home with a loan amount less than $134,841; • 3.5 or more percentage points for a subordinate-lien covered transaction with a loan amount greater than or equal to $80,905; or • 6.5 or more percentage points for a subordinate-lien covered transaction with a loan amount less than $80,905.