Posted January 7, 2025 —
As we approach 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
- 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
- The dollar amount thresholds under Regulation Z for HOEPA and QM-related loans have been adjusted as follows:
- For HOEPA loans, the adjusted total loan amount threshold for high-cost mortgages will be $26,968.
- The adjusted points-and-fees dollar trigger for high-cost mortgages will be $1,348.
- 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.
- For all categories of QMs, the thresholds for total points and fees 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.
- For open-end consumer credit plans under TILA, the threshold that triggers requirements to disclose minimum interest charges will remain unchanged at $1.00 for 2025.
https://www.govinfo.gov/content/pkg/FR-2024-12-02/pdf/2024-27553.pdf
Other Regulatory Thresholds and Limits
- The dollar amount of the maximum allowable charge for disclosures by a consumer reporting agency to a consumer pursuant to Fair Credit Report Act (FCRA) section 609 for the 2025 calendar year remains $15.50. https://www.govinfo.gov/content/pkg/FR-2024-11-29/pdf/2024-27695.pdf
- The exemption threshold for Regulation M (Consumer Leasing Act) will increase to $71,900, up from $69,500. https://www.govinfo.gov/content/pkg/FR-2024-10-15/pdf/2024-23276.pdf
- The FDIC Designated Reserve Ratio remains 2 percent for 2025. https://www.govinfo.gov/content/pkg/FR-2024-10-22/pdf/2024-24438.pdf
- Contribution limit for employees who participate in 401(k), 403(b), most 457 plans, and the federal government’s Thrift Savings Plan is increased to $23,500, up from $23,000. The limit on annual contributions to an IRA remains $7,000. https://www.irs.gov/newsroom/401k-limit-increases-to-23500-for-2025-ira-limit-remains-7000
- Multifamily loan purchase caps for Fannie Mae and Freddie Mac will be $73 billion for each enterprise, for a combined total of $146 billion. The caps reflect current market forecasts. FHFA will continue to require that at least 50 percent of Fannie’s and Freddie’s multifamily business be mission-driven affordable housing. https://www.fhfa.gov/sites/default/files/2024-11/2025-multifamily-loan-purchase-caps-fact-sheet.pdf
- The conforming loan limit values for mortgages to be acquired by Fannie Mae and Freddie Mac in 2025 for one-unit properties will be $806,500, an increase of $39,950 from 2024. https://www.fhfa.gov/news/news-release/fhfa-announces-conforming-loan-limit-values-for-2025
- FHA's nationwide forward mortgage limit “floor” and “ceiling” for a one-unit property in 2025 are $524,225 and $1,209,750, respectively. For 2025, the nationwide Home Equity Conversion Mortgage (HECM) limit will be $1,209,750 for all areas. https://www.hud.gov/program_offices/housing/sfh/lender/origination/mortgage_limits