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CFPB Raises Truth in Lending Act Exemption Thresholds, Reducing Regulatory Burden on Smaller Institutions

Posted by on January 8, 2026

Yesterday, the CFPB updated the asset-size exemption thresholds under Regulation Z, reducing regulatory burdens on smaller institutions.

  • First-Lien Higher-Priced Mortgage Loans: The exemption threshold has increased to $2.785 billion (from $2.717 billion). Creditors with assets below this amount as of December 31, 2025, and meeting other Regulation Z requirements, are exempt from establishing escrow accounts for higher-priced mortgage loans in 2026. This threshold also applies during a grace period for applications received before April 1, 2027.
  • Insured Depository Institutions and Credit Unions: The threshold has increased to $12.485 billion (from $12.179 billion). Institutions with assets at or below this amount on December 31, 2025, qualify for the exemption for loans consummated in 2026 and for certain first-lien transactions in 2027 with applications received before April 1, 2027.

The GoWest regulatory team advocates for implementing the maximum permissible annual adjustment to ensure alignment with prevailing economic conditions and market trends. These adjustments reflect a 2.5% CPI-W increase for the 12-month period ending November 2025. GoWest will continue to advocate for a substantial increase to exemption thresholds in recognition of the regulatory burden that reporting creates for smaller institutions.

Posted in Advocacy on the Move, Regulatory Advocacy.

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