The CFPB has finalized a series of annual inflation adjustments affecting mortgage lending, credit-card disclosures, consumer leases and credit-reporting fees, updates that credit unions, banks and financial services firms must implement by Jan. 1, 2026.
In one of the most significant changes, the CFPB raised the Truth in Lending Act (TILA) exemption threshold for consumer credit transactions not secured by real estate from $71,900 to $73,400. The Bureau said the adjustment reflects a 2.1% increase in the CPI-W from April 2024 to April 2025. The same threshold increase applies to consumer leases under Regulation M, meaning leases valued at $73,400 or more fall outside the Consumer Leasing Act's disclosure requirements.
A separate final rule updated Regulation Z, modifying thresholds tied to high-cost mortgages under the Home Ownership and Equity Protection Act (HOEPA). Beginning in 2026, a mortgage becomes subject to HOEPA if its total loan amount is $27,592 or less, or if points-and-fees exceed $1,380. For larger loans, the five-percent points-and-fees test continues to apply. The Bureau also adjusted both the APR-to-APOR spreads and points-and-fees caps for determining whether a loan meets the Qualified Mortgage (QM) definition, changes driven by a 2.3% CPI-U increase.
In a fourth filing, the CFPB raised the maximum allowable charge for a consumer reporting agency to provide a credit file disclosure, increasing the 2026 cap to $16.00, up from $15.50. The agency cited a cumulative 101% rise in CPI-U since 1997.
The CFPB emphasized that all four adjustments are routine, technical, and nondiscretionary, required annually under federal law. Still, the updates trigger system and disclosure changes for mortgage lenders, credit unions, auto-leasing providers and credit-reporting firms as they prepare for the 2026 compliance cycle.
The filings are scheduled to be published in the Federal Register on Monday.
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