Our job is to make yours a little easier. So, in case you missed their release, we’ve compiled 2024’s lending threshold changes (including historical data) and developed convenient tables to help you keep it all straight.
You can find all the 2024 lending thresholds by CLICKING HERE.
The CFPB released and updated the following thresholds for 2024:
- The HMDA threshold was increased from $54 million in 2023 to $56 million in 2024.
- The HPML Small Creditor Threshold was increased from $2.537 billion to $2.640 billion in 2024.
- The HPML Intermediate Creditor Threshold was increased from $11.374 billion to $11.835 billion in 2024
- The Reg Z exemption threshold amount is increased from $66,400 to $69,500 in 2024.
- The Reg Z Credit Card Safe Harbor Penalty Fees remain unchanged at $30 for a first violation and $41 for each subsequent violation.
- For open-end consumer credit plans under TILA, the threshold that triggers requirements to disclose minimum interest charges will remain unchanged at $1.00 in 2024.
- For HOEPA loans, the adjusted total loan amount threshold for high-cost mortgages in 2024 will be $26,092.
- For HPML loan exemption thresholds it will be $32,400 for 2024 up from $31,000 in 2023.
- The adjusted points-and-fees dollar trigger for high-cost mortgages in 2024 will be $1.305.
- For qualified mortgages (QMs) under the General QM loan definition in § 1026.43(e)(2), the thresholds for the spread between the annual percentage rate (APR) and the average prime offer rate (APOR) in 2024 will be:
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- 2.25 or more percentage points for a first-lien covered transaction with a loan amount greater than or equal to $130,461
- 3.5 or more percentage points for a first-lien covered transaction with a loan amount greater than or equal to $78,277 but less than $130,461
- 6.5 or more percentage points for a first-lien covered transaction with a loan amount less than $78,277
- 6.5 or more percentage points for a first-lien covered transaction secured by a manufactured home with a loan amount less than $130,461
- 3.5 or more percentage points for a subordinate-lien covered transaction with a loan amount greater than or equal to $78,277 or
- 6.5 or more percentage points for a subordinate-lien covered transaction with a loan amount less than $78,277.
- For all categories of QMs, the thresholds for total points and fees in 2024 will be:
- 3 percent of the total loan amount for a loan greater than or equal to $130,461
- $3,914 for a loan amount greater than or equal to $78,277but less than $130,461
- 5 percent of the total loan amount for a loan greater than or equal to $26, 092 but less than $78,277
- $1,305 for a loan amount greater than or equal to $16,208 but less than $26,092 and
- 8 percent of the total loan amount for a loan amount less than $16,308.
Let’s not forget CRA! The Federal Reserve Board and the Federal Deposit Insurance Corporation announced the 2024 updated asset-size thresholds used to define “small bank” and “intermediate small bank” under their Community Reinvestment Act (CRA) regulations.
Annual adjustments to these asset-size thresholds are based on the average change in the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W), which is a measure of inflation.
- Small bank means an institution that, as of December 31 of either of the prior two calendar years, had assets of less than $1.564 billion.
- Intermediate small bank means a small institution with assets of at least $391 million as of December 31 of both of the prior two calendar years and less than $1.564 billion as of December 31 of either of the prior two calendar years.
All final rules threshold updates were effective January 1, 2024.
Again, you can find the 2024 lending thresholds, and the annual thresholds for all lending compliance regulations, here. As always, if you have any questions or need additional guidance get in touch with us at support@mycomplianceresource.com.