HMDA Data: What’s Reported, Who Reports, and How It’s Used

Home Mortgage Disclosure Act data, known as HMDA data, is the public record of mortgage applications and loans that thousands of lenders must file every year. Congress created it in 1975 to answer a simple question: are lenders serving the communities where they operate?¹ The dataset covers roughly 4,768 institutions as of the 2025 release and captures most of the residential mortgage market, which makes it one of the most detailed public windows into how home credit moves through the United States.²

What Each Record Contains

Every application and originated loan generates a record with dozens of fields. Regulation C, the federal rule implementing HMDA, groups them into a few categories.³

Applicant Information

Lenders record the applicant’s ethnicity, race, sex, and age, along with the gross annual income relied on in the credit decision. When an applicant meets with the lender in person and declines to provide demographic information, the lender must note it based on visual observation or surname.³ These fields are what make fair-lending analysis possible. Without them, the data would show where money goes but not who receives it.

Loan Details

Each record shows the loan amount, whether the loan is FHA-insured, VA-guaranteed, or backed by the Rural Housing Service, and the purpose: purchase, refinance, home improvement, or cash-out refinance. The lender also reports the action taken (origination, approval but not accepted, denial, withdrawal, or file closed for incompleteness) and, for originated loans, the interest rate and the rate spread above the average prime offer rate.³

Property Information

Records identify the construction method (site-built or manufactured), whether the property will be a principal residence, second home, or investment property, and the location down to the census tract.³ Census tract coding is what lets researchers map lending against neighborhood demographics, income, and racial composition.

How the Public Version Protects Privacy

The full submissions lenders make to their regulators contain enough detail to identify individual borrowers, so the CFPB modifies the file before releasing it. The publicly available Modified Loan Application Register removes or alters the specific application date, exact credit score, exact borrower age, exact loan amount, property address, universal loan identifier, and automated underwriting results.⁴

HMDA records never include borrower names, Social Security numbers, or similar direct identifiers. The modifications target combinations of fields that could re-identify someone, such as a specific loan amount at a specific address on a specific date. The public dataset still supports serious research while reducing the chance any record can be traced to a particular borrower.

Where to Access HMDA Data

The CFPB and the Federal Financial Institutions Examination Council jointly publish the data on the FFIEC’s HMDA Platform.² Several tools are available depending on what you need.

The Snapshot National Loan-Level Dataset is a fixed copy of the data as finalized at the annual release. Use it for year-over-year comparisons, since later corrections do not change the snapshot.
The Dynamic National Loan-Level Dataset reflects corrections and resubmissions made after the initial release. Use it when you want the most current version.
The Data Browser is an interactive tool for building custom tables by lender, geography, loan type, and applicant demographics without downloading the full file.
The Modified Loan Application Register gives institution-level files showing every loan and application a specific lender reported, with the privacy modifications applied.

For large-scale research, the full datasets download in CSV and pipe-delimited formats. The most recent annual release, covering 2024 lending activity, was published on March 31, 2026.²

Which Lenders Must Report

Coverage matters when interpreting the data, because small lenders can fall outside the requirement. Regulation C sets different thresholds for depository institutions and independent mortgage companies.⁵

Banks, savings associations, and credit unions must file if they meet all three of these tests:

Assets above an inflation-adjusted threshold, set at $59 million for the 2026 reporting year.⁶
A home or branch office in a metropolitan statistical area as of the preceding December 31.⁵
At least 25 closed-end mortgages or at least 200 open-end lines of credit originated in each of the two preceding calendar years.⁵

Non-depository lenders face only the loan-volume tests; the asset-size and location tests do not apply to them.⁵ Smaller filers also qualify for a partial exemption that lets them skip 26 expanded fields, including credit score, debt-to-income ratio, interest rate, total loan costs, property value, and automated underwriting results. If you are working with the data and notice missing values in those columns, a partial-exemption filer is often the reason.⁷

How HMDA Data Gets Used

Fair Lending Enforcement

HMDA data is the starting point for most federal fair-lending investigations. The Department of Justice has described redlining cases as more than half of its fair-lending enforcement work, and those cases lean heavily on HMDA data to show that a lender avoided minority neighborhoods.⁸ The DOJ and CFPB also use the pricing fields to flag lenders whose rate spreads show statistically significant disparities across racial groups. Those disparities do not prove discrimination on their own. Investigators then obtain the lender’s internal files, including credit scores and underwriting policies, to test whether legitimate factors explain the gap. HMDA data is what tells regulators where to look.

Community Reinvestment Act Examinations

Bank examiners fold HMDA data into Community Reinvestment Act evaluations. During a CRA exam, regulators review a bank’s HMDA disclosure statements and loan application register to assess lending by borrower income and census tract income, both inside and outside its assessment areas.⁹ Examiners can also compare a bank against peer lenders using the aggregated data. A weak showing can drag down a CRA rating, which then affects the bank’s ability to expand through mergers and acquisitions.

Public Policy and Community Research

Government agencies use HMDA data to identify neighborhoods underserved by private capital and direct public investment accordingly, one of the purposes Congress spelled out when it passed the law.¹ Community organizations and academic researchers use the same files to produce reports on local housing markets, pinpoint areas with disproportionately high denial rates, and bring evidence to conversations with lenders about reinvestment. Because the data is free, public, and standardized across thousands of institutions, anyone can use it, not only regulators.

Data Quality and Enforcement

Lenders must submit annual data electronically to their federal supervisory agency by March 1 following the calendar year the data covers. An authorized representative certifies the submission, and the institution keeps a copy for at least three years.¹⁰

Enforcement is split among agencies by charter type. The CFPB has overall authority, and the OCC, FDIC, Federal Reserve, and NCUA supervise their respective institutions. The Secretary of Housing and Urban Development covers lenders not supervised by any of those agencies.¹¹ Penalties for data errors can be significant. The CFPB ordered Bank of America to pay $12 million in 2023 for widespread HMDA reporting errors, which signals that regulators take data quality as seriously as the reporting obligation itself.¹²

1
Office of the Law Revision Counsel. 12 USC Chapter 29 – Home Mortgage Disclosure
2
Consumer Financial Protection Bureau. 2025 HMDA Data on Mortgage Lending Now Available
3
eCFR. 12 CFR 1003.4 – Compilation of Reportable Data
4
Federal Register. Disclosure of Loan-Level HMDA Data
5
eCFR. 12 CFR Part 1003 – Home Mortgage Disclosure Regulation C
6
Consumer Financial Protection Bureau. Home Mortgage Disclosure Regulation C Adjustment to Asset-Size Exemption Threshold
7
Federal Register. Partial Exemptions From the Requirements of the Home Mortgage Disclosure Act Under the Economic Growth, Regulatory Relief, and Consumer Protection Act
8
Department of Justice. Fair Lending Enforcement
9
Federal Financial Institutions Examination Council. Large Institution CRA Examination Procedures
10
Consumer Financial Protection Bureau. 12 CFR 1003.5 – Disclosure and Reporting
11
Office of the Law Revision Counsel. 12 USC 2804 – Enforcement
12
Consumer Financial Protection Bureau. Bank of America, N.A.