Moving on Up – Reg M, V, and Z Threshold Increases for 2026
As the new year approaches, I know you have all been waiting for 2026 threshold updates. Last week, the CFPB delivered with five final rules that adjust the dollar thresholds used in Regulations M, V, and Z. All of the adjustments go into effect on January 1, 2026, so there is no reason to delay further.
Regulation Z, HOEPA, and Qualified Mortgages
The first rule amends Regulation Z (which implements the Truth in Lending Act (TILA)) regarding credit cards, the Home Ownership and Equity Protection Act of 1994 (HOEPA), and Qualified Mortgages (QM). For open-ended consumer credit plans under TILA (credit cards) the threshold that triggers requirements to disclose minimum interest charges will remain unchanged at $1.00 in 2026.
For HOEPA loans, the adjusted total loan amount threshold for high-cost mortgages1, under section 1026.32(a)(1)(ii)(A), was $26,968 in 2025 and will be $27,592 in 2026. The adjusted points-and-fees dollar trigger for high-cost mortgages, under section 1026.32(a)(1)(ii)(B), in 2026 will be $1,380, up from $1,348 in 2025.
For Qualified Mortgages (QMs), which are loans with less risky features and protections that make it more likely that a borrower will be able to afford the loan, the thresholds for the spread between the annual percentage rate (APR) and the average prime offer rate (APOR) [1] in 2026 will be:
| Loan Amount | Spread |
| ≥ $137,958 | ≥ 2.25 percentage points |
| ≥$82,775; < $137,957.99 | ≥ 3.5 percentage points |
| < $82,775 | ≥ 6.5 percentage points |
| < $137,958 (manufactured home) | ≥ 6.5 percentage points |
| ≥ $82,775 (subordinate-lien covered transaction) | ≥ 3.5 percentage points |
| < $82,775 (subordinate-lien covered transaction) | ≥ 6.5 percentage points |
For all categories of QMs, the thresholds for total points and fees in 2026 will be:
| Loan Amount | Total Points and Fees |
| ≥ $137,958 | 3 % of the total loan amount |
| ≥$82,775; < $137,958 | $4,139 |
| ≥$27,592; <$82,775 | 5 % of the total loan amount |
| ≥$17,245; <$27,592 | $1,380 |
| <$17,245 | 8 % of the total loan amount |
Special Appraisal Requirement Exemptions
The second rule is a joint rulemaking between the CFPB, the Federal Reserve Board, and the Office of the Comptroller of the Currency. It adjusts the threshold for exempting loans from special appraisal requirements under the TILA Higher Priced Mortgage Loan Appraisal rule. The exemption threshold for smaller loans was previously $33,500 and will increase to $34,200 in 2026.
Exempt Credit and Consumer Lease Transactions Under Reg Z and Reg M
The third and fourth rules are companion rules jointly made by the CFPB and the Federal Reserve Board to adjust the thresholds in Regulation Z and Regulation M for determining the exempt consumer credit transactions under TILA and the exempt consumer lease transactions under the Consumer Leasing Act (CLA). The thresholds for 2025 were $71,900 and will increase to $73,400 in 2026.
FCRA Disclosure Charges
The fifth rule updates Regulation V, the Fair Credit Reporting Act (FCRA) for adjusting the maximum allowable charge for disclosures by a consumer reporting agency to a consumer. The 2025 maximum was $15.50 and will increase to $16 in 2026.
The following table summarizes the changes discussed above, except for the QM's, which are already displayed in tabular form.
| Threshold Affected | 2025 Threshold | 2026 Threshold |
|
Trigger for min interest charges: HOEPA Total Loan Amt.: HOEPA Points-and-Fees: QMs:
|
$1 $26,968 $1,348 |
$1 $27,592 $1,380 See Above |
|
|
$33,500 |
$34,200
|
|
Reg Z - determining the exempt consumer credit transactions under TILA
|
$71,900 |
$73,400
|
|
Reg M - determining the exempt consumer credit transactions under the CLA
|
$71,900 | $73,400 |
|
|
$15.50 | $16.00 |