Compliance Journal January 2026
Special Focus Happy New Year - 2026 Brings Adjusted Regulatory Thresholds Happy New Year! As we step into 2026, there are many thresholds which have been adjusted by both state and federal regulators which go into effect now that the new year has arrived. Below is a collection of thresholds effective January 1, 2026. A link has been provided for each as reference. Regulation Z, TILA •
The exemption threshold for Regulation Z (Truth in Lending Act) will increase to $73,400, up from $71,900. https:// www.govinfo.gov/content/pkg/FR-2025-12-15/pdf/2025-22814.pdf
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The exemption threshold under Regulation Z for HPML appraisals will increase to $34,200, up from $33,500. https:// www.govinfo.gov/content/pkg/FR-2025-12-16/pdf/2025-22875.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:
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For creditors and their affiliates that regularly extended covered transactions secured by first liens, the asset-size threshold is adjusted to $2.785 billion, up from $2.717 billion; and
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The exemption threshold for certain insured depository institutions with assets of $10 billion or less is adjusted to $12.485 billion, up from $12.179 billion. https://www.govinfo.gov/content/pkg/FR-2026-01-07/ pdf/2026-00085.pdf
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 $27,592.
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The adjusted points-and-fees dollar trigger for high-cost mortgages will be $1,380.
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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 $137,958;
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3.5 or more percentage points for a first-lien covered transaction with a loan amount greater than or equal to $82,775 but less than $137,958;
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6.5 or more percentage points for a first-lien covered transaction with a loan amount less than $82,775;
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6.5 or more percentage points for a first-lien covered transaction secured by a manufactured home with a loan amount less than $13,958;
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3.5 or more percentage points for a subordinate-lien covered transaction with a loan amount greater than or equal to $82,775; or
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6.5 or more percentage points for a subordinate-lien covered transaction with a loan amount less than $82,775.