Rules in December 2024 Release

The FHA Single Family forward mortgage loan limits in ECS have been updated to reflect the 2025 limits announced by the Federal Housing Administration (FHA) on November 26, 2024, through Mortgagee Letter 2024-21.

Key Updates

• FHA sets forward mortgage limits based on the National Housing Act, adjusting annually.

• The nationwide mortgage limit "floor" for a one-unit property is $524,225, and the "ceiling" is $1,209,750.

FHA Loan Limits

As per HUD Handbook 4000.1, Section II.A.2.a.ii:

• Loan limits by MSA and county are available online at HUD Loan Limit Lookup.

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• Downloadable text files with full county listings are available at HUD File Layouts.

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• FHA's Maximum Mortgage Limits, including floor and ceiling areas, are published on the Maximum Mortgage Limits page.

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Special Exception Areas

Mortgage limits for the special exception areas of Alaska (AK), Hawaii (HI), Guam (GU), and the Virgin Islands (VI) are adjusted by FHA to account for higher costs of construction.

• One-unit: $1,814,625
• Two-unit: $2,323,450
• Three-unit: $2,808,325
• Four-unit: $3,490,300

The conforming loan limit values (CLLs) in ECS for mortgages acquired by Fannie Mae and Freddie Mac (the Enterprises) in 2025 have been updated to reflect the limits announced by the Federal Housing Finance Agency (FHFA) on November 26, 2024, through News Release FHFA Announces Conforming Loan Limit Values for 2025.

Key Updates

• The 2025 maximum CLL for one-unit properties will be $806,500, an increase of $39,950 from the 2024 limit of $766,550.

• Limits for multi-unit loans in 2025 are as follows:

  • Two-unit loans: $1,032,650
  • Three-unit loans: $1,248,150
  • Four-unit loans: $1,551,250

Special Exception Areas

Mortgage limits for the special exception areas of Alaska (AK), Hawaii (HI), Guam (GU), and the Virgin Islands (VI) are adjusted by FHFA to account for high-cost areas.

• One-unit: $1,209,750
• Two-unit: $1,548,975
• Three-unit: $1,872,225
• Four-unit: $2,326,875

The dollar amounts for several provisions in Regulation Z in ECS, specifically amounts for provisions implementing amendments to TILA under the Home Ownership and Equity Protection Act of 1994 (HOEPA), and the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), have been updated to reflect the 2025 values for QM, HOEPA and certain high cost points and fees thresholds announced by the Bureau of Consumer Financial Protection (Bureau) on November 20, 2024, effective for loans with a consummation date on or after January 1, 2025.

Key Updates

Qualified Mortgage Points and Fees Thresholds—

• The total points and fees for Qualified Mortgages cannot exceed the following based on the loan amount:

  • 3% for a loan amount of $134,841 or more.
  • $4,045 for a loan amount of $80,905 or more but less than $134,841.
  • 5% for a loan amount of $26,968 or more but less than $80,905.
  • $1,348 for a loan amount of $16,855 or more but less than $26,968.
  • 8% for a loan amount less than $16,855.

General Qualified Mortgage Price-Based Thresholds—

• First-lien covered transactions:

  • 2.25 percentage points for loan amounts $134,841 or more.
  • 3.5 percentage points for loan amounts of $80,905 or more but less than $134,841.
  • 6.5 percentage points for loan amounts less than $80,905.
  • 6.5 percentage points for loans secured by a manufactured home with a loan amount less than $134,841.

• Subordinate-lien covered transactions:

  • 3.5 percentage points for loan amounts $80,905 or more.
  • 6.5 percentage points for loan amounts less than $80,905.

HOEPA (High Cost) Loan Amount Thresholds—

• The total loan amount threshold for HOEPA loans changes from $26,092 to $26,968.
• The statutory fee trigger for HOEPA loans changes from $1,305 to $1,348.

The end date for the FHA Higher Priced Mortgage Loan (HPML) Mortgage Insurance Value (MI) has been extended for loans with a consummation date on or after January 1, 2025. As a result of this update, users will no longer receive an ERROR status message. Instead, users will receive either an ALERT, FAIL, or PASS status message, depending on whether the loan exceeds the HPML threshold.

Effective January 1, 2025, Kansas HB 2247 of 2024 repeals various provisions of the Kansas Uniform Consumer Credit Code (KS UCCC) (for Kansas MBA licensees) and creates certain of those provisions under the Kansas Mortgage Business Act (KS MBA). Certain substantive provisions will now only apply to "covered transactions" under the KS MBA, and accordingly, related provisions under the KS UCCC and Kansas Usury Law will be sunset.

Currently, ECS applies rules based on the KS UCCC and Kansas Usury Law for loans secured by real property in Kansas. The KS MBA applies only to specific transactions made by licensees, while older provisions under the KS UCCC remain active for lenders other than Kansas MBA licensees.

Beginning January 1, 2025, ECS will:

• Sunset older rules under the KS UCCC, which will no longer apply.

• Apply new or relocated rules under the KS MBA and KS Usury Law for covered transactions, including:

  • Junior lien mortgages and first lien mortgages with loan-to-value (LTV) exceeding 100%, unless guaranteed by a U.S. federal agency.
  • Usury Law provisions for first lien loans with LTV ≤ 100%.

For lenders exempt from KS MBA licensing, ECS will apply the KS UCCC to junior lien loans and first lien loans with LTV > 100%, except for federally guaranteed loans.

ECS has been updated to resolve an issue where FAIL status messages were incorrectly triggered for HELOC loans submitted in Massachusetts when no Draw Amount was entered.

With this update, users will now correctly receive a FAIL status message under the following conditions:

• If a principal and interest amount is entered without a Draw Amount.
• If neither Draw Amount (field ID 1888) nor principal and interest amount is entered, but the late fee exceeds $10.

You can now submit New Jersey loans to ECS with an updated maximum principal amount threshold for high-cost home loan determinations under the New Jersey Home Ownership Security Act of 2002 (N.J.S.A. 46:10B-22 et seq.).

Certain limitations under the Pennsylvania Loan Interest and Protection Law (LIPL) adjust every year. The dollar amount for this threshold in ECS has been updated to reflect the 2025 limit for this threshold announced by the Department of Banking on November 6, 2024, through Notice 51 Pa.B. 6929.

Under Title 32 V.S.A. § 3108 (Establishment of Interest Rate), the Commissioner of Taxes is required to set the interest rate by December 15th each year for calculating interest on underpayments and overpayments of tax liabilities for the upcoming calendar year.