2026 Thresholds & Free Tool Updates

With 2026 still feeling pretty new, do you ever start to think, “What did I forget?” Something that can slip through the cracks are the regulatory threshold changes that generally take effect on January 1^st each year.

Here’s a quick list (not all-inclusive) of some common ones:

Regulation Z

• Loan Amount Exemption to determine if certain loans are subject to Regulation Z
• Points & Fees to determine High-Cost Mortgage status
• Loan Amount Exemption for appraisal requirements on Higher-Priced Mortgage Loans (HPMLs)
• Points & Fees for determining Qualified Mortgage (QM) status
• Asset Size for certain Small Creditor QMs*
• Rate Spread for determining General QM status
• The asset size for the additional HPML escrow account exemption*

HMDA*

• The asset-size threshold for determining whether your financial institution is subject to HMDA (Please note this is only one of several criteria that must be met).

*Threshold was not yet available at the time this blog went to print.

For more information on these threshold changes, refer to the January edition of our Banking on BCC Magazine.

Free Lending Tool Updates

In light of the changes to the points and fees for determining QM status and the rate spread used, in part, for determining General QM status, we’ve updated our ATR/QM Repayment Ability and Risk Requirements Matrix. Version 6.4 is available now in the Free Lending Tools on our website.

Additionally, if you are a HMDA Reporter, make sure you are using the 2026 Filing Instructions Guide (FIG). While the 2026 version did not include any substantive changes, we have updated our HMDA Data Guide with a few technical changes. Version 4.2 is available now in the Free Lending Tools on our website.