AWACSMortgage compliance intelligence from Flightline

CFPB · Final rules and official interpretations FR Doc. 2024-23277 · Published

Appraisals for Higher-Priced Mortgage Loans Exemption Threshold: 2025 increase to $33,500

The OCC, Board and CFPB raise the HPML appraisal exemption threshold for smaller loans from $32,400 to $33,500, effective January 1, 2025, by adding new official interpretation comments. The increase follows the 3.4 percent CPI-W rise and applies the previously established annual adjustment method.

Review recommendedEffective Jan 1, 2025All checks passedRead the interpretations ↗ (opens in a new tab)

Loan impact

From the interpretations text · verified

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.

Affected area
WaiverGuide Section 1026.35(c)(2)(ii)
Effective
Jan 1, 2025
Applicability confidence
Verified: every row above is supported by the source text
Supporting quotes from the interpretations
  • affected areas“Effective January 1, 2025, the exemption threshold amount is increased from $32,400 to $33,500.”
  • guide sections“A transaction is exempt under § 1026.35(c)(2)(ii) if the creditor makes an extension of credit at consummation that is equal to or below the threshold amount in effect at the time of consummation.”
  • guide sections“A transaction is exempt under § 34.203(b)(2) if the creditor makes an extension of credit at consummation that is equal to or below the threshold amount in effect at the time of consummation.”
  • guide sections“A transaction is exempt under § 226.43(b)(2) if the creditor makes an extension of credit at consummation that is equal to or below the threshold amount in effect at the time of consummation.”

What changed

From the interpretations text · Section 12 CFR 1026.35(c)(2)(ii), comment 35(c)(2)(ii)-3.xii
RequirementPreviouslyNow
HPML appraisal exemption threshold for 2025RelaxedPreviously: Threshold amount of $32,400 for 2024Threshold amount is $33,500 from January 1, 2025 through December 31, 2025

Also affected: Sections 1026.35(c)(2)(ii), 34.203(b)(2), 226.43(b)(2).

What to do

AWACS interpretation · not source language

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.

QC implications

  • Sample higher-priced mortgage loans consummated from January 1, 2025 through December 31, 2025 that were treated as exempt from the appraisal requirement, and confirm the extension of credit at consummation was equal to or below $33,500.
  • Check that the threshold used was the one in effect at the time of consummation, so that $32,400 was not applied to loans consummated in 2025 and $33,500 was not applied to loans consummated in 2024.

Source and record

Version 1 · archived

Checks passed

  • Schema valid
  • Effective quotes verbatim
  • Document ID appears in the source
  • Doc id matches catalog
  • Mandatory status is backed by requirement language
  • Mandatory entries have requirement language
  • Published on present
  • Title summary length
  • Controlled vocabulary
  • No placeholder tokens
  • Source link resolves
  • Loan impact quotes verbatim
  • Loan impact vocabulary
  • Changes quoted
  • Impact type consistent
  • Every required change is backed by obligation language
  • Only new or tightened changes are marked required
  • Loan impact covers every required change
  • Quotes are complete sentences
  • Unflagged must
  • Diff complete
  • Mandatory date resolved
  • Audience verbatim
  • Scope residential
  • Out of scope
  • Published in window
  • Interpretation schema valid
  • Interpretation separate