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A $250,000 first-lien loan closes in 2026. Under the 2026 qualified mortgage limits, what is the most it can carry in points and fees and still be a qualified mortgage?
For a loan amount of $137,958 or more, points and fees may not exceed 3% of the total loan amount (12 CFR 1026.43(e)(3)(i); 2026 figure, effective Jan 1, 2026). 3% x $250,000 = $7,500. $4,139 is the flat cap for loans from $82,775 to $137,957, and $12,500 (5%) is the HOEPA points-and-fees trigger, not the QM limit. $20,000 applies the 8% cap meant only for the smallest loans. Source: 12 CFR 1026.43(e)(3)(i) and comment 43(e)(3)(ii)-1.xii; 2026 adjustment, 90 FR 57890 (Dec 15, 2025), effective Jan 1, 2026 (as at 11 Oct 2026).
Using the 5% HOEPA trigger instead of the 3% QM cap.
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