Agencies Announce Threshold for Smaller Loan Exemption from Appraisal Requirements for Higher-Priced Mortgage Loans

WASHINGTON, D.C. — The Consumer Financial Protection Bureau (CFPB), Federal Reserve Board, and Office of the Comptroller of the Currency (OCC) today announced that the threshold for exempting loans from special appraisal requirements for higher-priced mortgage loans during 2016 will remain $25,500.

The threshold amount will be effective January 1, 2016, and is the same threshold that applied in 2015–based on the annual percentage decrease in the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W) as of June 1, 2015.

The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 amended the Truth in Lending Act to add special appraisal requirements for higher-priced mortgage loans, including a requirement that creditors obtain a written appraisal based on a physical visit to the home's interior before making a higher-priced mortgage loan. The rules implementing these requirements contain an exemption for loans of $25,000 or less and also provide that the exemption threshold will be adjusted annually to reflect increases in the CPI-W. If there is no annual percentage increase in the CPI-W, the agencies will not adjust this exemption threshold from the prior year.

The Federal Register notice is available at: https://federalregister.gov/a/2015-30097

Where this stands in 2026

The $25,500 figure above applied to 2016. This exemption is adjusted annually against the CPI-W, so it has moved every year since and the 2015 announcement now describes the mechanism rather than the current number.

$25,500 then, $34,200 now

For 2026 the threshold exempting smaller loans from the special appraisal requirements for higher-priced mortgage loans is $34,200, up from $33,500, effective 1 January 2026, based on a 2.1% annual increase in the CPI-W as of 1 June 2025. The agencies announced it jointly, as they did in 2015, and the rule is published at Appraisals for Higher-Priced Mortgage Loans Exemption Threshold.

What has not changed

The underlying requirement is the same one the Dodd-Frank Act added to the Truth in Lending Act: for a higher-priced mortgage loan above the threshold, the creditor must obtain a written appraisal based on a physical visit to the interior of the home. The exemption is a dollar cutoff on that obligation, not a different standard, and the CPI-W mechanism means that if the index does not rise, the agencies leave the figure alone — which is exactly what happened in the year this post was written.

What a filer does about it this cycle

The threshold interacts with whether a loan is higher-priced at all, which turns on the rate spread. If you are checking a single file, the rate spread calculator runs the APOR comparison one loan at a time; across a portfolio it is calculated automatically in Comply HMDA/CRA/SBL against FFIEC tables that refresh weekly.