SAFE MLO candidates and working MLOs who need to separate the 2026 Regulation Z mortgage thresholds

2026 HOEPA, QM, and HPML Thresholds: NMLS Study Guide

A source-checked 2026 guide to HOEPA points-and-fees, General QM APR/APOR and fee tiers, and the $34,200 HPML appraisal exemption.

By SafeMLO Coach Editorial Team. Reviewed against official NMLS, CSBS, CFPB, and Prometric materials. Published August 2, 2026. Reviewed August 2, 2026.

Direct answer

The 2026 numbers belong to three different decisions. HOEPA uses a $27,592 loan-amount split and a $1,380 dollar trigger for its points-and-fees coverage test. General QM uses 2026 loan-amount tiers for both the APR-versus-APOR pricing condition and the points-and-fees limit, with $137,958 and $82,775 as key pricing breakpoints. HPML uses $34,200 only as the small-loan exemption from the special appraisal requirements in Regulation Z section 1026.35(c). These figures are effective January 1, 2026; the HPML appraisal threshold expressly applies through December 31, 2026. None of the three tests substitutes for the other two.

Annual threshold questions become difficult when the numbers are memorized as one list. The same dollar amount can appear in more than one rule, while similar-sounding acronyms lead to different legal results. The reliable approach is to classify the test before touching the arithmetic.

This guide covers only the 2026 figures named in the current CFPB rule, Federal Register notice, and Regulation Z interpretations: the HOEPA points-and-fees coverage test, General QM pricing and points-and-fees conditions, and the HPML small-loan appraisal exemption. It is educational, not legal or transaction-specific advice. For an actual loan, use current Regulation Z, official interpretations, and your compliance process.

Decision guide

Situation	Best move	Why it matters
You are asked whether points and fees make a mortgage high-cost under HOEPA	Use the section 1026.32 HOEPA points-and-fees test	For 2026, the first split is whether the total loan amount is at least $27,592; the result is high-cost coverage, not QM status.
You are asked whether a covered transaction meets General QM pricing	Identify lien position, loan amount, manufactured-home status, APR, APOR, and the rate-set date	Section 1026.43 uses six APR/APOR categories, and the applicable spread is a QM eligibility condition.
You are asked whether total points and fees fit within General QM	Use the five 2026 QM points-and-fees tiers	The percentage or fixed-dollar cap changes at $17,245, $27,592, $82,775, and $137,958.
You are asked whether a small HPML is exempt from special appraisal requirements	Compare the amount of credit extended at consummation with $34,200	An amount at or below $34,200 meets this particular appraisal exemption; $34,201 does not.
A loan passes one of the three tests	Continue to the other applicable tests and conditions	Passing HOEPA points-and-fees, General QM pricing, or the HPML small-loan appraisal test does not establish the other results.

First decide what result the question is asking for

HOEPA is a coverage question: do the transaction's terms make it a high-cost mortgage under section 1026.32? This guide focuses on the points-and-fees route, but HOEPA also has APR and prepayment-penalty coverage triggers. Passing the points-and-fees test alone does not rule out HOEPA coverage.

General QM is an eligibility question under section 1026.43. The loan must satisfy the applicable APR/APOR pricing condition and stay within the points-and-fees limit, along with the rest of the General QM requirements. Neither calculation by itself proves the loan is a QM.

The $34,200 HPML figure is narrower. It asks whether an HPML is small enough for one exemption from the special appraisal requirements in section 1026.35(c). It does not decide whether the loan is an HPML, whether an escrow rule applies, whether it is high-cost, or whether it is a QM.

2026 HOEPA points-and-fees coverage

For a total loan amount of $27,592 or more, the mortgage is high-cost under the points-and-fees test if points and fees exceed 5 percent of the total loan amount. At exactly 5 percent, this trigger is not crossed because the rule says exceeds.

For a total loan amount below $27,592, compare points and fees with the lesser of 8 percent of the total loan amount or $1,380. The smaller result is the trigger. If points and fees exceed that result, the transaction is high-cost under this test.

The boundary belongs to the upper tier: a total loan amount of exactly $27,592 uses the 5 percent rule. The fixed $1,380 figure is not automatically the trigger for every smaller loan. On a $10,000 total loan amount, 8 percent is $800, so $800 is the lesser amount.

2026 General QM APR-versus-APOR pricing tiers

For a first-lien covered transaction of at least $137,958, the APR/APOR spread must stay below 2.25 percentage points. For a first lien of at least $82,775 but less than $137,958, the spread must stay below 3.5 points. For a first lien below $82,775, the spread must stay below 6.5 points.

A first-lien transaction secured by a manufactured home and below $137,958 uses the 6.5-point category. A subordinate-lien transaction of at least $82,775 uses 3.5 points; a subordinate lien below $82,775 uses 6.5 points.

The comparison uses APOR for a comparable transaction as of the date the interest rate is set. The thresholds are stated as spreads the APR may not equal or exceed. For certain adjustable- or step-rate loans that can change within the first five years, section 1026.43 contains a special APR determination, so the disclosed starting APR is not always the right input.

2026 General QM points-and-fees tiers

For a loan amount of at least $137,958, total points and fees may not exceed 3 percent of the total loan amount. For at least $82,775 but less than $137,958, the limit is $4,139. For at least $27,592 but less than $82,775, the limit is 5 percent.

For at least $17,245 but less than $27,592, the limit is $1,380. Below $17,245, the limit is 8 percent of the total loan amount. Here, equality with the applicable cap does not cross the limit; the regulation says a transaction is not a QM if points and fees exceed it.

Notice the trap: $27,592 and $1,380 also appear in the 2026 HOEPA adjustment, but the structures are not the same. HOEPA has two loan-amount branches for the points-and-fees trigger. General QM has five points-and-fees tiers and asks a different legal question.

2026 HPML small-loan appraisal exemption

From January 1 through December 31, 2026, an extension of credit at or below $34,200 qualifies for the small-loan exemption from the special HPML appraisal requirements in section 1026.35(c). The threshold increased from $33,500 for 2025.

Equality matters: $34,200 is within this exemption, while $34,201 is above it. The amount is evaluated at consummation. If an older exempt loan is later refinanced with a new extension above the threshold then in effect, the old exemption does not carry over merely because the new loan replaces it.

Keep the scope narrow. Section 1026.35(c) contains other transaction exemptions and detailed appraisal rules. A loan below $34,200 is not automatically outside HPML treatment, and a loan above $34,200 is not automatically subject to an appraisal if another exemption applies.

Worked example 1: one fee amount, two different tests

Assume, only for classification practice, that the correctly calculated total loan amount is $20,000 and points and fees are $1,500. For HOEPA, the loan is below $27,592. Eight percent of $20,000 is $1,600, and the lesser of $1,600 or $1,380 is $1,380. Because $1,500 exceeds $1,380, the loan crosses the HOEPA points-and-fees trigger.

For General QM points and fees, $20,000 falls in the $17,245-to-below-$27,592 tier, whose cap is also $1,380. Since $1,500 exceeds the cap, the transaction fails that General QM condition. The arithmetic happens to use the same dollar figure, but the legal conclusions are different: HOEPA coverage under one trigger versus failure of one QM requirement.

Do not extend the example further without more facts. It does not tell us the HOEPA APR result, the General QM pricing result, whether every other QM condition is met, or whether the transaction is an HPML.

Worked example 2: pricing passes, but the review is not finished

Assume a first-lien covered transaction that is not secured by a manufactured home has a $100,000 loan amount. The APR is 8.00 percent and the comparable APOR on the rate-set date is 4.60 percent. The spread is 3.40 percentage points. Because $100,000 falls from $82,775 to below $137,958, the 2026 General QM pricing boundary is 3.5 points. A 3.40-point spread is below that boundary, so this pricing condition is satisfied.

Now assume correctly calculated total points and fees are $4,000. The applicable General QM cap for this loan-amount tier is $4,139, so the fee condition is also within the limit. At $4,140 it would exceed the cap.

The correct conclusion is deliberately modest: the example satisfies these two General QM conditions on the stated assumptions. It does not establish final QM status. Product features, term, payment calculation, underwriting, and the remaining requirements still need review.

Worked example 3: the $34,200 boundary

Assume a transaction has already been classified as an HPML and the amount of credit extended at consummation is exactly $34,200. It meets the 2026 small-loan exemption from the special section 1026.35(c) appraisal requirements because the rule includes amounts equal to the threshold.

Change only the amount to $34,201. The transaction no longer qualifies for this small-loan exemption. The creditor would then check the other exemptions and, if none applies, follow the appraisal requirements.

This example does not say that $34,201 makes a loan an HPML. HPML status must already be determined under the rule's separate pricing definition. The dollar threshold enters only after that classification and only for the appraisal requirement addressed here.

Common mistakes to avoid

Using $34,200 as the line between an HPML and a non-HPML: Use $34,200 only for the small-loan exemption from section 1026.35(c) appraisal requirements. HPML status is a separate APR/APOR analysis.
Using the General QM points-and-fees tier to answer a HOEPA question: Name the legal result first. HOEPA asks high-cost coverage; General QM asks whether a covered transaction can qualify as a QM.
Treating 2.25, 3.5, and 6.5 as interest rates: They are percentage-point spreads between APR and APOR for the applicable General QM category, not the note rate or APR by itself.
Ignoring the words at least, less than, exceeds, and equal to or below: Write the interval before calculating. Boundary words decide the tier and whether equality passes or fails.
Concluding that a loan is a QM because it passes the pricing and fee limits: Those are only part of the General QM definition. Product features, term, underwriting, and other section 1026.43 conditions still matter.
Using the face amount without checking the regulation's defined amount: HOEPA total loan amount, QM total loan amount, and HPML amount of credit extended are rule terms. In a real file, use the defined calculation and current compliance procedure.

Study checklist

Write the legal result first: HOEPA coverage, General QM eligibility, or HPML appraisal exemption.
Use 2026 figures only for transactions and comparisons to which the 2026 rule applies.
For HOEPA points and fees, split at a total loan amount of $27,592.
Below $27,592, calculate both 8 percent and $1,380, then use the lesser amount.
For General QM pricing, identify lien position, loan amount, manufactured-home status, APR, APOR, and rate-set date.
For General QM points and fees, place the loan in one of five tiers before comparing the fee total.
Treat General QM pricing equality as failing the below-threshold condition; treat fee-cap equality as within the cap.
Use $34,200 only for the 2026 HPML small-loan appraisal exemption and test the amount at consummation.
Do not infer final HOEPA, QM, or HPML treatment from one threshold test.
For a live transaction, recheck current Regulation Z, official interpretations, and company compliance guidance.

Related guides

What are the 2026 HOEPA points-and-fees thresholds?

At a total loan amount of $27,592 or more, points and fees exceeding 5 percent trigger high-cost coverage under this test. Below $27,592, the trigger is points and fees exceeding the lesser of 8 percent of the total loan amount or $1,380.

What are the key 2026 General QM pricing amounts?

$137,958 and $82,775 are the main loan-amount breakpoints. Depending on lien position, amount, and manufactured-home status, the APR must remain below the applicable 2.25-, 3.5-, or 6.5-percentage-point spread over APOR.

What are the 2026 General QM points-and-fees tiers?

The limits are 3 percent at $137,958 or more; $4,139 from $82,775 to below $137,958; 5 percent from $27,592 to below $82,775; $1,380 from $17,245 to below $27,592; and 8 percent below $17,245.

Is $34,200 the 2026 HPML threshold?

It is the 2026 small-loan exemption threshold for the special HPML appraisal requirements in section 1026.35(c), not the threshold that determines whether a loan is an HPML.

When are these 2026 thresholds effective?

The official adjustments are effective January 1, 2026. The HPML appraisal threshold is expressly listed for January 1 through December 31, 2026; the HOEPA and General QM figures are the annual 2026 adjustments.

Does passing the General QM pricing and fee tests prove a loan is a QM?

No. Those are two conditions within the General QM definition. The loan must also satisfy the other applicable product, term, payment, underwriting, and Regulation Z requirements.

Next action

Build three separate reference cards labeled HOEPA high-cost coverage, General QM eligibility, and HPML special-appraisal exemption. On each card write the legal result, the required inputs, the 2026 boundaries, and the equality rule. Then work the examples below without looking at the numbers. If you cannot name the card before calculating, the classification step still needs practice.

Sources used to verify this page

SafeMLO Coach is an independent study aid. It is not NMLS, CSBS, Prometric, a state regulator, a lender, a school, or a law firm. Always confirm licensing, renewal, testing, fees, waiting periods, and continuing education requirements with official sources.

CFPB: Regulation Z Section 1026.32: Requirements for High-Cost Mortgages - Current Regulation Z text and official interpretations checked August 2, 2026, including the 2026 HOEPA points-and-fees figures of $27,592 and $1,380.
Federal Register / GovInfo: Truth in Lending (Regulation Z) Annual Threshold Adjustments for 2026, 90 FR 57890 - Official final rule checked August 2, 2026. It gives the HOEPA and General QM dollar thresholds effective January 1, 2026, including the APR/APOR and points-and-fees tiers.
CFPB: Regulation Z Section 1026.35: Requirements for Higher-Priced Mortgage Loans - Current Regulation Z text and official interpretations checked August 2, 2026. The small-loan HPML appraisal exemption is $34,200 for January 1 through December 31, 2026 and is tested at consummation.
CFPB: Regulation Z Section 1026.43: Ability-to-Repay and Qualified Mortgages - Current Regulation Z text and official interpretations checked August 2, 2026, including all 2026 General QM APR/APOR and points-and-fees tiers.
CFPB: Appraisals for Higher-Priced Mortgage Loans Exemption Threshold - CFPB final-rule page checked August 2, 2026 confirming the HPML appraisal-exemption threshold increased to $34,200 effective January 1, 2026.