The Home Mortgage Disclosure Act requires your financial institution to do four things if it is a covered lender: collect and record specified data on every mortgage application it handles, submit that loan-level data to federal regulators each year, make a public disclosure statement and a modified loan application register available through the FFIEC, and post lobby notices telling customers where to find the data. What HMDA requires financial institutions to provide is, in short, both the raw reporting to regulators and the public-facing records and notices that let anyone examine how the institution lends.1eCFR. 12 CFR 1003.5 – Disclosure and Reporting
The Annual Data Submission
Covered institutions submit their loan application registers electronically to federal regulators by March 1 following each calendar year of data collection. The largest lenders carry a heavier cycle. An institution that originated or received at least 60,000 applications and covered loans (excluding purchases) in the preceding year must also file quarterly, within 60 days after the end of each of the first three calendar quarters.1eCFR. 12 CFR 1003.5 – Disclosure and Reporting
The data behind those submissions has expanded sharply since a 2018 overhaul roughly doubled the required fields. For each covered transaction, institutions record:2eCFR. 12 CFR 1003.4 – Compilation of Reportable Data
- Loan characteristics: loan amount, interest rate, loan term, total points and fees, non-amortizing features, and whether the loan is a high-cost mortgage.
- Applicant demographics: ethnicity, race, sex, age, and gross annual income, plus whether that information was supplied by the applicant or observed by the loan officer.
- Credit profile: credit score and scoring model, debt-to-income ratio, combined loan-to-value ratio, and the automated underwriting system result.
- Property details: property value, census-tract location, construction method, number of units, and whether the property is a primary residence, second home, or investment property.
- Action taken: originated, denied, withdrawn, approved but not accepted, or closed for incompleteness; if denied, the reasons.
- Loan type and purpose: conventional, FHA, VA, or Rural Housing Service; home purchase, refinancing, cash-out refinancing, or home improvement.
The Public Disclosure Statement
Each year the Federal Financial Institutions Examination Council prepares a disclosure statement for every reporting institution based on the data it submitted for the prior calendar year.1eCFR. 12 CFR 1003.5 – Disclosure and Reporting The FFIEC, not any single agency, does this work: it standardizes how figures from thousands of lenders are compiled and published.
The statement organizes a lender’s activity by census tract. Anyone reviewing it can see how many loans a bank made in a given neighborhood and for how much money. It covers home purchase loans, refinancings, home improvement loans, and open-end lines of credit secured by a dwelling. The institution does not have to produce the statement itself; it has to make sure the FFIEC-prepared version is available to the public through the notice process described below.
The Modified Loan Application Register
Where the disclosure statement summarizes lending at the neighborhood level, the modified Loan Application Register goes application by application. The LAR records every individual application a lender processes during the year. Before the register goes public, the CFPB modifies it to strip out information that could identify individual applicants, such as names, dates of birth, and property addresses below the census-tract level.1eCFR. 12 CFR 1003.5 – Disclosure and Reporting
Even with identifiers removed, the modified LAR retains the action taken, the loan amount, the property type, the census tract, and the applicant’s ethnicity, race, sex, and age.2eCFR. 12 CFR 1003.4 – Compilation of Reportable Data Your institution’s obligation is to ensure the modified LAR is accessible to the public; the CFPB hosts the file on the FFIEC platform after processing your submission.
Lobby Notices and Written Requests
Every covered institution must post a general notice in the lobby of its home office and each branch located in a metropolitan area. The notice tells customers that the institution’s HMDA data shows the geographic distribution of its loans, the demographics of its applicants, and information about approvals and denials, and directs them to the CFPB’s HMDA website.3eCFR. 12 CFR Part 1003 – Home Mortgage Disclosure (Regulation C) – Section 1003.5(e) The regulation supplies suggested language.
There is a second layer. Once the FFIEC notifies an institution that its disclosure data is available, the institution has three business days to give any member of the public who requests the data a written notice pointing them to the modified LAR on the CFPB’s website.4National Credit Union Administration. Additional Information About Home Mortgage Disclosure Act Data Collection Requirements for Calendar Year 2018 and Changes to Data Notices Examiners look for both notices during compliance reviews.
Whether Your Institution Is Covered
HMDA does not reach every lender. A depository institution (bank, savings association, or credit union) is covered only if it meets all of the following: its total assets exceed the annually adjusted threshold published by the CFPB; it has a home or branch office in a metropolitan statistical area; it originated at least one home purchase loan or refinancing secured by a first lien on a one-to-four-unit dwelling in the preceding year; it is federally insured or regulated (or the loan is federally insured or intended for sale to Fannie Mae or Freddie Mac); and it meets the applicable loan-volume threshold.5Consumer Financial Protection Bureau. HMDA Institutional Coverage A nondepository institution such as an independent mortgage lender faces similar location and volume tests but no asset-size threshold.
The loan-volume thresholds are 25 closed-end mortgage loans in each of the two preceding calendar years and 200 open-end lines of credit in each of the two preceding calendar years.6Consumer Financial Protection Bureau. Home Mortgage Disclosure Act FAQs An institution below both thresholds is not required to report, though it may do so voluntarily.
Transactions You Do Not Have to Report
Even a covered institution reports only qualifying residential mortgage activity. The regulation excludes:7eCFR. 12 CFR 1003.3 – Exempt Institutions and Excluded Transactions
- Loans used primarily for agricultural purposes.
- Loans made primarily for business or commercial purposes, unless the loan also qualifies as a home purchase, home improvement, or refinancing loan.
- Temporary financing, including construction-only loans.
- Loans secured by unimproved land.
- Any loan or line of credit under $500.
- Buying an interest in a pool of loans, purchasing servicing rights alone, or acquiring loans through a merger.
- Loans originated or purchased while acting in a fiduciary capacity.
What Happens If You Get It Wrong
Institutions that fail to collect, record, or report HMDA data accurately face civil money penalties assessed per day. The penalty structure has three tiers that escalate with culpability: unknowing violations draw the lowest amounts, reckless violations the middle, and knowing violations the highest. The CFPB adjusts the maximums annually for inflation. For 2025, the most recent published adjustment, the daily maximums were $770 for Tier 1, $7,701 for Tier 2, and $38,506 for Tier 3.
The dollar exposure is only part of the picture. Regulators use HMDA data as a primary input in fair-lending examinations and Community Reinvestment Act evaluations, so incomplete or inaccurate reporting can pull scrutiny across an institution’s whole compliance program. Persistent data-quality problems can weigh on a CRA rating, which can in turn affect the ability to open new branches or complete mergers.