In the December 2, 2024 issue of the Federal Register (89 FR 95080 click here), the Consumer Financial Protection Bureau established the following 2025 thresholds for high-cost and qualified mortgages under §§1026.32 and 1026.43, respectively..
HOEPA (High-cost Mortgages) 2025 Threshold Adjustments
Effective January 1, 2025, a consumer loan secured by the consumer’s principal dwelling and not otherwise exempt is a high-cost mortgage based on the total points and fees payable by the consumer under §1026.32(a)(1)(ii) if the points and fees exceed: (A) 5 percent of the total loan amount for a loan with a loan amount of $26,968 or more, or (B) the lesser of 8 percent of the total loan amount or $1,348 for a loan with a loan amount of less than $26,968. Comment 32(a)(1)(ii)–1.xi is added to reflect the new $1,348 threshold amount for 2025. Comment 32(a)(1)(ii)–3.xi is added to reflect the new $26,968 threshold loan amount for 2025.
Qualified Mortgages 2025 Threshold Adjustments APOR Spread
Effective January 1, 2025, for purposes of determining whether a covered transaction is a qualified mortgage under the §1026.43(e)(2) general definition, a covered transaction is not a qualified mortgage unless the transaction’s annual percentage rate does not exceed the average prime offer rate (APOR) as of the date the interest rate is set by: (A) For a first-lien covered transaction with a loan amount greater than or equal to $134,841, 2.25 or more percentage points; (B) For a first-lien covered transaction with a loan amount greater than or equal to $80,905 but less than $134,841, 3.5 or more percentage points; (C) For a first-lien covered transaction with a loan amount less than $80,905 , 6.5 or more percentage points; (D) For a first-lien covered transaction secured by a manufactured home with a loan amount less than $134,841, 6.5 or more percentage points; (E) For a subordinate-lien covered transaction with a loan amount greater than or equal to $80,905, 3.5 or more percentage points; (F) For a subordinate-lien covered transaction with a loan amount less than $80,905, 6.5 or more percentage points. Comment 43(e)(2)(vi)–3.iv is added to reflect the new threshold amounts for 2025.
Full Memorandum