On Oct. 4, Fed, OCC, CFPB issued final rules, official interpretations.
Agencies finalized amendments adjusting the 2025 threshold for higher-priced mortgage loans that are subject to special appraisal requirements, exemption.
OCC also issued press release on the 2025 threshold for higher-priced mortgage loans.
Implementing section 129H of the Truth in Lending Act (TILA) (15 USC 1601 et. seq.).
Exemption threshold for higher-priced mortgage loans that are subject to special appraisal requirements will increase from $32,400 to $33,500, effective Jan. 1, 2025.
Based on the 3.4 percent annual percentage increase in the Consumer Price Index for Urban Wage Earners and Clerical Workers, known as CPI-W, as of Jun. 1, 2024.
DFA added special appraisal requirements for higher-priced mortgage loans to TILA.
Including that creditors obtain a written appraisal based on a physical visit to the interior of the home before making a higher-priced mortgage loan, with exemption.
Exemption for loans of $25,000 or less, adjusted annually to reflect CPI-W increases.
Fed, CFPB Consumer Transactions
Regulation Z (12 CFR 226) and Regulation M (12 CFR 213) generally will apply to consumer credit transactions and consumer leases of $71,900 or less in 2025.
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.
Effectiveness
The changes come into effect on Jan. 1, 2025.
Oct. 2024 Fed Reg Final Rules
On Oct. 15, 2024, Agencies published final rules, interpretations in the federal register.
Final rules re loan exemption threshold, Reg M and Reg Z effective on Jan. 1, 2025.
Dec. 2024 CFPB Final Rules
On Dec. 2, 2024, CFPB issued final rule amending regulation, interpretations for Reg Z.
Revised amounts for provisions implementing TILA as per CPI; effective Jan. 1, 2025.
Regulators
CFPB; Fed; OCC
Entity Types
Bank; CNSM; CU; MG Orig; Servicer; Thrift
Reference
89 FR 95080, 12/2/2024; 89 FR 82938, 89 FR 82934, 89 FR 82931, 10/15/2024; CFPB: PR, RF, 10/4/2024; Fed: PR, RF R-1841, R-1842, R-1843, RIN 7100 AG 82; RIN 7100- AG 83; RIN 7100-AG 84; OCC: PR 2024-113, RF OCC-2024-0013, RIN 1557-AF28, 10/04/2024; TILA; Reg Z; Reg M; Citation: 15 USC 1601; *12 CFR* 226, 213;
