2026
HMDA (Regulation C): 2026 asset-size exemption threshold raised to $59 million
Applies to: Banks, savings associations and credit unions with assets of $59 million or less as of December 31, 2025 are exempt from HMDA data collection in 2026.
What to review: Compliance may review whether the raised threshold, now $59 million for 2026 data collection and up from $58 million, exempts the institution from collecting 2026 data, keeping in mind that data required to be collected in 2025 must still be reported. AWACS interpretation
2025
FCRA Preemption of State Laws: Interpretive Rule Replacing Withdrawn 2022 Rule
Applies to: Consumer reporting agencies, credit report users and furnishers subject to the FCRA; the rule is non-binding guidance on State law preemption.
What to review: No change is mandatory, so compliance may review the CFPB's clarification that the FCRA generally preempts State laws touching broad areas of credit reporting and its confirmed withdrawal of the 2022 interpretive rule, which is non-binding guidance applicable October 28, 2025. AWACS interpretation
2024
HMDA (Regulation C): asset-size exemption threshold raised to $58 million for 2025
Applies to: Banks, savings associations and credit unions with assets of $58 million or less as of December 31, 2024 are exempt from collecting HMDA data in 2025.
What to review: No change is mandatory. Start by checking whether your institution, as a bank, savings association or credit union, had assets at or below $58 million (up from $56 million) as of December 31, 2024. If it did, it may choose not to collect HMDA data in 2025 under the relaxed threshold effective January 1, 2025, but it must still report data it was required to collect in 2024. AWACS interpretation
Appraisals for Higher-Priced Mortgage Loans Exemption Threshold: 2025 increase to $33,500
Applies to: Higher-priced mortgage loans consummated from January 1, 2025 through December 31, 2025, for which the appraisal exemption threshold is now $33,500.
What to review: No change is mandatory, so first review how the higher threshold of $33,500, effective January 1, 2025 for loans consummated through December 31, 2025, relaxes the earlier $32,400 amount. The lender may use the higher amount when deciding whether a higher-priced mortgage loan is exempt from the appraisal requirement. AWACS interpretation