HMDA reporting.

HMDA reporting is how a lender complies with the Home Mortgage Disclosure Act of 1975: it records each covered application, origination and purchase on the LAR every quarter and files the LAR once a year, under Regulation C, 12 CFR part 1003.⁠[3]⁠[4]

Its purposes are public: to show whether lenders serve their communities' housing needs, to guide public investment, and to help identify possible discriminatory lending patterns.⁠[3] Lenders file with the CFPB on the HMDA Platform, which counts as filing with their own federal regulator.⁠[1]⁠[5]

Is every HMDA error a violation?

No. An unintentional error isn't a violation if it happened despite procedures reasonably adapted to avoid it, and quarterly data recorded in good faith can be corrected before the annual filing (12 CFR 1003.6(b)–(c)).⁠[3] The CFPB found Washington Federal Bank hadn't kept such procedures, so its errors were “intentional and not bona fide errors.”⁠[6]

How is HMDA data used in fair lending reviews?

As a screen. The agencies use HMDA data in fair lending and Community Reinvestment Act exams,⁠[7] and a disparity is a reason to pull loan files, not proof of discrimination. Since July 21, 2026, Regulation B says the Equal Credit Opportunity Act doesn't authorize disparate-impact liability; the CFPB's rule leaves HMDA unchanged.⁠[8]

In 2023, most closed-end HMDA reporters were small banks and credit unions, but most of the loans came from mortgage companies.

• 42.2% of closed-end reporters in 2023, 2,152 of 5,103, originated fewer than 100 closed-end loans. Together they made about 2.2% of reported originations.⁠[9]
• 56.1% of reported closed-end originations in 2023 came from independent mortgage companies. Credit unions made 11.4%.⁠[9]
• 14.6% more institutions reported for 2023 than for 2022, an increase the CFPB says is likely due to the lower closed-end threshold.⁠[9]

A bank, savings association or credit union must report the HMDA data it collects in 2026 if it passes all five tests below; a for-profit nondepository lender needs only the location and loan-volume tests (12 CFR 1003.2(g)).⁠[3]

What is the HMDA asset threshold for 2026?

$59 million. Banks, savings associations and credit unions at or below it on December 31, 2025, don't collect HMDA data in 2026. The CFPB adjusts the threshold every year by the CPI-W; it was $58 million for 2025. The exemption doesn't excuse reporting data the institution had to collect in 2025.⁠[4]

Will the HMDA threshold change?

Possibly. Executive Order 14393, signed March 13, 2026, directs the CFPB to consider proposing Regulation C amendments that would raise the asset threshold for smaller banks, exclude inquiries from HMDA, and reduce reporting burdens.⁠[10] The order doesn't amend the rule; until the CFPB finalizes one, the tests above apply.

What is the HMDA partial exemption?

Insured banks, savings associations and credit unions that originated fewer than 500 closed-end loans in each of the two preceding years can skip 26 of Regulation C's 48 data points for those loans. Open-end lines are tested separately.⁠[11] The skipped items include the universal loan identifier, property address, rate spread, credit score, loan costs and the underwriting ratios. A bank rated “needs to improve” on its two most recent CRA exams, or “substantial noncompliance” on the latest, doesn't qualify (12 CFR 1003.3(d)).⁠[3]

The HMDA LAR has one row for each covered application, origination and purchase. Regulation C requires 48 data points (12 CFR 1003.4(a)), reported in 110 data fields.⁠[3]⁠[11]⁠[2]

Which HMDA fields do examiners test first?

The 37 key fields. The Federal Reserve, FDIC and OCC focus transaction testing on them; they include the application date, loan amount, action taken and its date, census tract, applicant demographics and income, credit score, interest rate, the underwriting ratios and property value. Examiners may review other fields too.⁠[2]

HMDA data are due by March 1 of the following year: data collected in 2026 are due Monday, March 1, 2027. A deadline that falls on a Saturday or Sunday moves to the Monday, which is why 2025 data were due March 2, 2026 (12 CFR 1003.5(a)(1)).⁠[3] Three other clocks run alongside it.

Record each quarter's data30 calendar days after quarter-end

Data go on the register within 30 calendar days after the end of the quarter in which you took final action. Good-faith errors corrected before the annual filing aren't violations.

12 CFR 1003.4(f), 1003.6(c)(1)⁠[3]

Quarterly filing for large reporters60 calendar days after Q1, Q2 and Q3

An institution that reported at least 60,000 covered loans and applications for the preceding year, excluding purchased loans, also files its data for each of the first three quarters.

12 CFR 1003.5(a)(1)(ii)⁠[3]

The annual filingMarch 1 of the following year

File on the HMDA Platform with your Legal Entity Identifier, correct or confirm every edit, and have an authorized representative with knowledge of the data certify that it is accurate and complete. Keep a copy of the register for at least three years.

12 CFR 1003.5(a)(1)(i), (iii), (a)(3)⁠[3]⁠[5]

Public notices3 business days after the FFIEC's notice

Once the FFIEC says your disclosure statement is available, make a written notice available at your home office and each branch in an MSA, saying it can be obtained on the CFPB's website. A similar notice covers your modified LAR, and a general notice about your HMDA data goes up in those lobbies.

12 CFR 1003.5(b)–(e)⁠[3]

HMDA edits are the checks the HMDA Platform runs on a register before it can be submitted.⁠[5] Clearing them doesn't make the data right: an income of $85,000 passes every edit whether the underwriter relied on $85,000 or $58,000. Only the loan file can tell.

Examiners require a resubmission when their sample finds too many errors in one field. Under the FFIEC's HMDA Examiner Transaction Testing Guidelines, they check a random sample of LAR rows against the loan files, and a field that reaches the threshold must be corrected across the whole register and resubmitted.⁠[7]

Dates within three calendar days, loan amounts within $1,000 and income rounding don't count toward the thresholds. Examiners can still order a resubmission below the threshold when errors would make the data unreliable, such as withdrawn applications coded as denials, or when reportable loans were left off.⁠[7]

A HMDA violation can bring civil money penalties (12 CFR 1003.6(a)).⁠[3] Four CFPB actions show what drew them.

• Write your procedures down. The bona fide error defense depends on procedures reasonably adapted to avoid errors.⁠[3]
• Test fields against the file, not just the edits. Start with the 37 key fields.⁠[2]
• Run the examiners' sample on yourself. The FFIEC's sample sizes and thresholds show which fields would fail while there's still time to fix them across the register.⁠[7]
• Train for the demographic questions. Ask however the application is taken, read the questions aloud on the phone, and use visual observation or surname only for in-person applicants who don't answer.⁠[3]

Why HMDA data reviews take so long

Checking one row means opening the loan file in several places. When every row takes that long, review gets rationed to a sample, and the errors outside it are filed under your certification. Compliance operations covers where a compliance team's other hours go.

Socratix AI coworkers take on the gathering. For every row on the register, they pull the source documents from each system, compare them with the LAR, and hand your analysts each mismatch with the evidence and a recommendation. Your team still makes every call — it just stops spending filing season assembling the picture.

Examiners test a register field by field against the loan file whatever the lender's size.⁠[7] AI coworkers check every row instead of a sample, so the people you have spend their time on the judgment calls. Regulators work the same way: in GAO's 2025 review, most said AI outputs inform their staff's decisions but aren't the sole basis for them.⁠[15]

1. GatherPulls the documents behind each row, from the application to the rate lock, into one view per loan.
2. AssessCompares every reported field with those documents and Regulation C's definitions, and flags each mismatch with the document it came from.
3. RecommendProposes the correction with the evidence and a plain-language reason. Your analyst decides.
4. LearnLearns from each decision — your policies, your loan products, your team's judgment — and every step is logged for the examiner.

Related guides

• Compliance operations What compliance costs a community bank or credit union, and where the hours go.
• SAR filing Deadlines, the narrative, continuing activity and confidentiality for suspicious activity reports.
• BSA compliance The Bank Secrecy Act program: pillars, reports, records and the 2026 rule changes.