CFPB/Fed/OCC increase exemption thresholds for appraisal requirement, Regs Z and M

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The CFPB, Fed, and OCC have announced that they are increasing exemption thresholds that are subject to annual inflation adjustments.  Effective January 1, 2025 through December 31, 2025, these exemption thresholds are increased as follows:

  • The 2025 threshold for higher-priced mortgage loans that are subject to special appraisal requirements will increase from $32,400 to $33,500.
  • Regulation Z 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.
  • Regulation M generally also will apply to consumer credit transactions and consumer leases of $71,900 or less in 2025.

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