What is the HPML appraisal threshold for 2025?

Asked by: Burdette Dietrich  |  Last update: May 25, 2026
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The Higher-Priced Mortgage Loan (HPML) appraisal exemption threshold for 2025 is $33,500. Effective from January 1, 2025, through December 31, 2025, this adjusted threshold means loans at or below this amount are exempt from the special written appraisal requirements. This is an increase from the $32,400 threshold in 2024.

What is the HPML appraisal threshold for 2026?

Effective January 1, 2026, the exemption threshold amount is increased from $33,500 to $34,200. This amount is based on the CPI-W in effect on June 1, 2025, which was reported on May 13, 2025 (based on April 2025 data).

Do HPML loans require an appraisal?

The rules establish a general requirement that a written appraisal be obtained in connection with making an HPML. The written appraisal must be performed by a certified or licensed appraiser, and it must involve a physical property visit of the interior of the property by the appraiser.

What is the FHFA loan limit for 2025?

The new ceiling loan limit in high-cost markets will be $1,209,750, which is 150% of $806,500. The previous ceiling was $1,149,825. In its news release, FHFA said that because of rising home values, the ceiling loan limits will be higher in all but six U.S. counties or county equivalents in 2025.

What is the CFPB threshold for 2026?

The CFPB and Federal Reserve announced 2026 adjustments to several transaction thresholds. The threshold for higher-priced mortgage loans subject to special appraisal requirements is increasing to $34,200 (from $33,500) on Jan. 1.

NMLS Exam - Section 35 of TILA: Higher Priced Mortgage Loans (HPML)

35 related questions found

What are the qualified mortgage thresholds for 2025?

For all categories of QMs, the thresholds for total points and fees in 2025 will be 3 percent of the total loan amount for a loan greater than or equal to $134,841; $4,045 for a loan amount greater than or equal to $80,905 but less than $134,841; 5 percent of the total loan amount for a loan greater than or equal to ...

What is the conforming limit for 2026?

2026 Baseline Conforming Loan Limits (Most Areas):

1-unit home: $832,750. 2-unit home: $1,066,250.

What is the Hoepa limit for 2025?

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.

What is the FHA loan limit for 2025 in PA?

The “floor” (or the lowest loan limit) is calculated at 65% of the conforming loan limit, which in 2025 equals $524,225 for a single-family property. The ceiling (or highest loan limit for high-cost areas) for 2025 is $1,209,750, which is calculated at 150% of the conforming loan limit.

What is the FHA loan update for 2025?

FHA changes in 2025 focus on streamlining appraisals, updating loss mitigation/servicing rules (effective Oct 1), revising residency requirements for non-permanent residents (effective May 25), and setting higher loan limits (baseline $524,225 for 2025), while also phasing out some COVID-era flexibilities and rescinding certain appraisal forms/protocols to reduce lender burdens and expand property eligibility, impacting both new loans and existing homeowners in default.

What are the requirements for HPML?

Regulation Z defines an HPML as a mortgage secured by a borrower's principal dwelling with an APR that is at least 1.5% higher (for a first lien) or at least 3.5% higher (for a second lien) than the average prime offer rate (APOR) for a comparable transaction as of the rate lock date.

What is the difference between a 1007 and a 1025 appraisal?

Form 1025 is also used by appraisers to assess income properties. It differs from the 1007 in that it is used to assess duplexes, triplexes, and fourplexes.

What loans don't require an appraisal?

Personal loans and high limit credit cards aren't attached to home value, so there's no appraisal at all. But borrowers pay for this convenience with much higher interest rates. Still, this might work for a short-term need.

How to avoid HPML?

How to avoid HPML loans

  1. Don't take out an FHA loan.
  2. Boost your credit score.
  3. Make a bigger down payment.
  4. Ask the seller to pay closing costs.
  5. Reconsider buying a manufactured home.

What loans are excluded from HPML?

TILA section 129D(c)(2), as amended by the EGRRCPA, requires the Bureau to issue regulations to exempt from the HPML escrow requirement any loan made by an insured depository institution or insured credit union secured by a first lien on the principal dwelling of a consumer if: (1) The institution has assets of $10 ...

What causes a loan to be HPML?

Your mortgage will be considered a higher-priced mortgage loan (HPML) if the APR is a certain percentage higher than the APOR, depending on what type of loan you have: First-lien mortgages: If your mortgage is a first-lien mortgage, the lender of this mortgage will be the first to be paid if you go into foreclosure.

What is the mortgage limit for 2025?

In most of the United States, the 2025 CLL value for one-unit properties will be $806,500, an increase of $39,950 (or 5.2 percent) from 2024.

What is the FHA 85% rule?

The FHA 85% rule refers to a past guideline for cash-out refinances limiting the loan to 85% Loan-to-Value (LTV) and a specific rule for identity-of-interest transactions (like buying from family) where borrowers couldn't finance more than 85% of the home's value unless exceptions applied, such as renting from the family member for at least six months prior. While the general cash-out LTV is now 80%, the 85% rule still applies to certain related-party sales, requiring a 15% down payment unless an exception is met, notes FHA.com. 

What is the 3 7 3 rule in mortgage?

The 3-7-3 Rule in mortgages isn't a loan type but a federal timeline from the TILA-RESPA Integrated Disclosure (TRID) rule, ensuring borrower protection by mandating disclosures within 3 business days of application, a 7-business-day wait between the initial Loan Estimate and closing, and another 3-day wait if significant changes (like APR) occur, giving borrowers time to review costs before committing to a loan.

Will FHA loan limits increase in 2026?

Yes, FHA loan limits increased for 2026, with the national floor rising to $541,287 for single-family homes in most areas, and the ceiling in high-cost areas increasing to $1,249,125, effective for cases filed January 1, 2026, and later, to keep pace with rising home values. These limits vary by location and property size, reflecting the Federal Housing Administration's mandate to adjust annually based on median home prices and conventional conforming loan limits set by the FHFA.

What are the thresholds for QM in 2026?

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 2026 will be: 2.25 or more percentage points for a first-lien covered transaction with a loan amount greater than or ...