HUD's Qualified Mortgage Rule: Annual Threshold Adjustments to the Points and Fees Limit

The Consumer Financial Protection Bureau (CFPB) issued a final rule entitled "Truth in Lending (Regulation Z) Annual Threshold Adjustments (CARD ACT, HOEPA and ATR/QM)" on August 15, 2014. The final rule re-calculated the annual dollar amounts for the points and fees limit in CFPB's "qualified mortgage" definition to reflect the annual percentage change in the Consumer Price Index in effect on June 1, 2014. HUD's "qualified mortgage" definition incorporates CFPB's qualified mortgage points and fees limit and the requirement that the points and fees limit be adjusted annually. This document clarifies that all annual adjustments to the qualified mortgage points and fees limit issued by the CFPB to reflect the Consumer Price Index apply to HUD's points and fees limit provision, including CFPB's most recent final rule.