CFPB issues annual inflation adjustments

The CFPB has issued a final rule making inflation adjustments to Regulation Z that impact HOEPA loans and Qualified Mortgages, where appropriate. For open-end consumer credit plans, the threshold that triggers requirements to disclose minimum interest charges will remain unchanged at $1.00 in 2025.

For HOEPA loans, the adjusted total loan amount threshold for high-cost mortgages in 2025 will be $26,968.

The adjusted points-and-fees dollar trigger for high-cost mortgages in 2025 will be $1,348.

For qualified mortgages (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) in 2025 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.

For all categories of QMs, the thresholds for total points and fees in 2025 will be 3 percent of the total loan amount for a loan greater than or equal to $134,841; $4,045 for a loan amount greater than or equal to $80,905 but less than $134,841; 5 percent of the total loan amount for a loan greater than or equal to $26,968 but less than $80,905; $1,348 for a loan amount greater than or equal to $16,855 but less than $26,968; and 8 percent of the total loan amount for a loan amount less than $16,855.

The CFPB also announced the maximum amount consumer reporting agencies may charge consumers for making a file disclosure to a consumer under the Fair Credit Reporting Act (FCRA) will remain unchanged at $15.50, effective for 2025.

These amendments have been posted in the BankersOnline Regulations pages for sections 1026.32 and 1026.43 of Regulation Z and Appendix O to Regulation V.