Reg Agencies Move to Simplify CRA Compliance and Index Thresholds

12/18/25

The Consumer Financial Protection Bureau (CFPB) announced this week that it has finalized five rules adjusting certain dollar thresholds across Regulations Z, M, and V. These routine annual adjustments reflect changes in the Consumer Price Index and are intended to ensure that statutory thresholds keep pace with inflation. All five rules take effect January 1, 2026.

Updates to Regulation Z (Truth in Lending Act)
The first final rule amends Regulation Z, which implements the Truth in Lending Act (TILA), by adjusting several dollar thresholds tied to higher-risk mortgage lending. These updates affect provisions related to Home Ownership and Equity Protection Act (HOEPA) loans, as well as thresholds used in determining qualified mortgage status. While largely technical in nature, these changes are important for mortgage lenders to incorporate into their compliance systems ahead of the 2026 effective date.

Higher-Priced Mortgage Loan Appraisal Threshold
The second rule is a joint action by the CFPB, the Federal Reserve Board, and the Office of the Comptroller of the Currency. It updates the loan amount threshold used to exempt certain transactions from the special appraisal requirements that apply to higher-priced mortgage loans under TILA. This adjustment determines when an additional appraisal is required, including a physical inspection, and is particularly relevant for banks engaged in residential mortgage lending.

Consumer Credit and Consumer Lease Exemptions (Regulations Z and M)
The third and fourth rules, issued jointly by the CFPB and the Federal Reserve Board, adjust the dollar thresholds that define which consumer credit and consumer lease transactions are exempt from TILA and the Consumer Leasing Act.

• The Regulation Z update affects the exemption threshold for consumer credit transactions.
• The Regulation M update affects the exemption threshold for consumer lease transactions.

These thresholds play an important role in determining whether certain higher-dollar transactions fall outside the scope of detailed disclosure and substantive requirements.

Regulation V (Fair Credit Reporting Act) Disclosure Fees
The fifth and final rule amends an appendix to Regulation V, which implements the Fair Credit Reporting Act. The change adjusts the maximum amount that a consumer reporting agency may charge a consumer for certain disclosures in 2026.

Regulation Threshold New Amount for 2026

Reg Z - HOEPA total loan amount High-cost mortgage trigger $27,592

Reg Z - HOEPA points-and-fees trigger HOEPA point trigger $1,380

Special Appraisal Exemption (HPML) Exemption threshold $34,200

Reg Z Consumer Credit & Reg M Leasing Exemption thresholds $73,400

Reg V - Consumer disclosure charge cap Max allowable fee $16.00

In other news the Office of the Comptroller of the Currency proposed a simplified Community Reinvestment Act strategic plan framework intended to reduce compliance burden for community banks. The proposal is designed to make the CRA strategic plan option more practical and less resource-intensive for banks with assets of up to $30 billion.

Under current rules, banks may choose to have their CRA performance evaluated under an approved strategic plan instead of the standard CRA performance tests. In practice, however, the existing strategic plan process has proven to be complex and difficult to navigate, discouraging many community banks from using the option.

The OCC's proposal seeks to reverse that trend by offering clearer, more detailed guidance on the measurable goals and required elements of a CRA strategic plan. It would also streamline the process for drafting and submitting a plan for OCC approval, lowering the administrative and compliance hurdles associated with this alternative framework.