CFPB Announces 2023 Threshold Adjustment for HPML Appraisals

The CFPB, together with the Office of the Comptroller of the Currency and the Board of Governors of the Federal Reserve System, recently posted the annual adjustment to appraisal requirements for higher-priced mortgage loans (“HPMLs”). The new threshold will apply to loans in an amount not exceeding $31,100.

HPMLs are subject to additional appraisal requirements under Section 35 of Regulation Z, including the requirement to obtain two independent appraisals in some circumstances. 12 C.F.R. 1026.35(c). However, these rules do not apply to loans in the amount of $25,000 or less, with the $25,000 amount to be adjusted annually based on any annual percentage increase in the Consumer Price Index for Urban Wage Earners and Clerical Workers (“CPI-W”) as of June 1, each year.

The Bureau of Labor Statistics reported the CPI-W on May 11, 2022 (based on data from April 2021 to April 2022). The CPI-W reflects an 8.9 percent increase over the 2022 threshold of $28.500, resulting in a new threshold of $31,000 that will be in effect as of January 1, 2023.

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