On December 18, 2014 the Office of the Comptroller of the Currency, Federal Reserve Board, and Consumer Financial Protection Bureau issued a final rule amending the threshold amounts for determining whether a higher-priced mortgage loan (HPML) is exempt from the appraisal requirements set forth (inter alia) in 12 CFR § 1026.35(c) (and used to determine whether the loan is a “higher-risk mortgage” or not).
This exemption amount changes annually. For 2015, the amount will be $25,500 (up from $25,000). See 12 CFR Pt. 1026, Supp. I, Paragraph 35(c)(2)(ii) – (1)(ii) and 79 FR 78296 (2014) for details.
This threshold amount is used in our field entitled “Higher-Risk HPML” (Field 67269) which is used for configuration purposes (e.g. configuring the “Notice of Right to Receive Copy of Appraisal Report”; Cx17904). We have modified the mapping for this field to use the updated threshold amount.
In addition, the threshold amount for determining whether certain loans are subject to Regulation Z or not has also been modified. This amount also changes yearly and, for 2015, the amount is $54,600 (up from $53,500). See 12 CFR Pt. 1026, Supp. I Paragraph 3(b) – (1)(vi) and 79 FR 56485 (2014) for details.
While this exemption is only applicable to non-real estate secured loans, Iowa requires certain disclosures to appear on a promissory note when the loan amount is less than or equal to the Regulation Z exemption threshold (see Iowa Code Ann. §§ 537.3203 & 537.3211). We have configured these disclosures to print based off of the field entitled “Loan Amount Less Than or Equal to Reg Z Threshold Amount” (Field 81938), of which the threshold amount is a determining factor. We have modified the mappings for this field so that it reflects the updated threshold amount.
These changes took effect on January 1, 2015. If you have any questions or concerns, please contact Client Support at 1.800.497.3584.
January 5, 2015