CFPB Issues Final Rule Regarding Annual Threshold Adjustments for 2016 HOEPA and QM Loans
By Anna DeSimone
September 22, 2015 the Consumer Financial Protection Bureau (CFPB) issued a final rule amending the regulatory text and official interpretations for Regulation Z, implemented under the Truth in Lending Act (TILA). The regulation requires annual updating of the dollar amounts of thresholds pertaining to the Home Equity Protection Act (HOEPA) loans and the Qualified Mortgage (QM) rule. The adjustments are based on the Consumer Price Index.
The final rule is effective on January 1, 2016. The revised amounts and thresholds are shown below:
HOEPA loans
- Adjusted total loan amount threshold is $20,350
- Adjusted statutory fee trigger is $1,017
Qualified Mortgage (QM) thresholds
- 3 percent of the total loan amount for a loan greater than or equal to $101,749
- $3,052 for a loan amount greater than or equal to $61,050 but less than $101,749
- 5 percent of the total loan amount for a loan greater than or equal to $20,350 but less than $61,050
- $1,017 for a loan amount greater than or equal to $12,719 but less than $20,350
- 8 percent of the total loan amount for a loan amount less than $12,719
About the Author
Anna DeSimone is President and Founder of Bankers Advisory and Principal of CliftonLarsonAllen LLP. She can be reached at
Anna DeSimone founded Bankers Advisory in 1986 and is a nationally recognized authority in residential mortgage lending. She has received numerous industry awards and has authored more than 40 best practices guides and hundreds of articles.
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