The HMDA Loan Application Register is the standardized, loan-level record that covered mortgage lenders must compile and submit each year to the Consumer Financial Protection Bureau, documenting every mortgage application and loan action they took during the calendar year. Each entry captures roughly 110 data fields about a single transaction, from applicant demographics and loan terms to the census tract of the property. The register is filed under Regulation C (12 CFR Part 1003), which implements the Home Mortgage Disclosure Act, and the data is then released publicly so regulators, researchers, and community groups can see where mortgage credit is flowing and where it is not.
What the Register Records
The LAR is a chronological log. Every covered application and loan action gets its own entry, and the institution records the disposition: originated, approved but not accepted, denied, withdrawn by the applicant, or closed for incompleteness. Loans the institution purchased are also entered.
The fields on each entry fall into several groups:
- Applicant demographics: ethnicity, race, sex, age, and gross annual income of the applicant and any co-applicant.
- Loan characteristics: loan type (conventional, FHA-insured, VA-guaranteed, and so on), purpose (home purchase, refinancing, home improvement, cash-out refinancing), and loan amount.
- Action taken and the date of that action.
- Pricing and underwriting: interest rate, rate spread compared to the average prime offer rate, origination charges, lender credits, total loan costs, debt-to-income ratio, and the credit score relied on.
- Property location: state, county, and census tract.
- Institutional identifiers: the institution’s Legal Entity Identifier (LEI) and a Universal Loan Identifier (ULI) for each transaction, which begins with the institution’s LEI.
The LEI requirement has applied since January 1, 2019, and every filer must include it, with no exceptions.
Who Has to File for 2026
Regulation C splits covered institutions into two groups, and each has its own gate.
Depository Institutions
Banks, savings associations, and credit unions must file for 2026 data collection if they meet all of the following:
- Assets above $59 million as of December 31, 2025. Institutions at or below that figure are exempt. The threshold adjusts each year with the CPI; the 2026 figure reflects a 2.5 percent average CPI-W increase for the 12 months ending November 2025, rounded to the nearest million.
- A home or branch office in a Metropolitan Statistical Area on the preceding December 31.
- At least one first-lien home purchase loan or refinancing on a one-to-four-unit dwelling originated in the preceding calendar year.
- A federal nexus: federally insured or regulated, or having originated a loan that was federally insured, guaranteed, or intended for sale to Fannie Mae or Freddie Mac.
- At least 25 closed-end mortgage loans originated in each of the two preceding calendar years, or at least 200 open-end lines of credit in each of the two preceding calendar years.
Nondepository Institutions
For-profit mortgage lenders that are not banks, savings associations, or credit unions — independent mortgage companies, for instance — are covered if they had an MSA office and cleared the same loan-volume thresholds (25 closed-end originations or 200 open-end lines of credit in each of the two preceding years). There is no asset-size exemption for these lenders.
Transactions That Stay Off the LAR
Knowing what to omit matters as much as knowing what to report. Regulation C excludes several categories:
- Temporary financing: bridge, swing, and construction-only loans meant to be replaced by permanent financing.
- Agricultural loans, whether closed-end or open-end.
- Business or commercial loans, unless they also qualify as a home purchase loan, home improvement loan, or refinancing.
- Loans originated or purchased in a fiduciary capacity.
- Loans secured by unimproved land, unless the institution knows the borrower will build or place a dwelling on it within two years.
- Purchases of interests in pools of mortgage loans (such as mortgage-backed securities) or partial interests in a single loan.
- Loans acquired through a merger, acquisition, or purchase of all branch assets and liabilities.
- Loans or applications under $500.
If an institution falls below the loan-volume threshold for closed-end or open-end loans, the corresponding loan type is also excluded from its filing.
Partial Exemption for Smaller Institutions
The Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018 created a partial exemption that lets qualifying insured depository institutions and insured credit unions skip a significant number of data fields. To qualify, the institution must have originated fewer than 500 closed-end mortgage loans, or fewer than 500 open-end lines of credit, in each of the two preceding calendar years. It also cannot have received a CRA rating of “needs to improve” on each of its two most recent exams, or “substantial noncompliance” on its most recent exam.
Qualifying institutions still file a LAR, but they can skip roughly two dozen fields — including the Universal Loan Identifier, property address, rate spread, credit score, reasons for denial, total loan costs, and origination charges. Core fields stay mandatory: loan type, loan purpose, loan amount, action taken, and applicant demographics. The LEI is not covered by the exemption. Every filer reports it.
When and How to File
The annual LAR submission is due March 1 following the calendar year the data covers. When March 1 falls on a weekend, the deadline moves to the next Monday. For 2025 data, the CFPB confirmed that submissions received by March 2, 2026, would be timely.
Filing happens electronically through the CFPB’s HMDA Platform. The platform runs uploaded data through automated edits and validation checks for formatting errors, logical inconsistencies, and missing fields. Anything that fails must be corrected and resubmitted before the filing is accepted. An authorized representative of the institution with knowledge of the data must certify its accuracy and completeness.
Quarterly Filing for the Largest Institutions
Institutions that reported at least 60,000 combined originated covered loans and applications in the preceding calendar year also file quarterly. Purchased loans do not count toward that threshold. Quarterly filers submit data for the first three quarters within 60 calendar days after the end of each quarter. Fourth-quarter data folds into the annual submission.
What Becomes Public
Each year the CFPB publishes loan-level HMDA data that anyone can download. To protect borrower privacy, the agency modifies the file before release. Excluded from the public data: the Universal Loan Identifier, property address, application date, action-taken date, credit score, mortgage loan originator identifier, and automated underwriting system results. Other fields — loan amount, age, debt-to-income ratio, property value — appear in modified form, typically as ranges rather than exact figures.
Institutions also have a local disclosure duty. When a member of the public asks for HMDA data, the institution must provide a written notice explaining that its modified LAR is available on the CFPB’s website. Providing the modified LAR itself is optional, and the institution may charge a reasonable fee for reproduction. The notice must remain available for three years after the calendar year the data covers.
Enforcement, Resubmission, and Retention
Federal supervisory agencies examine institutions’ HMDA compliance management systems, looking at written policies, internal controls, staff training, audit schedules, and board and senior-management oversight. Examiners run transactional testing to verify submitted data.
When errors turn up, the resubmission trigger depends on file size. The CFPB’s guidelines set a 10 percent error rate for institutions with fewer than 100,000 LAR entries, and a 4 percent error rate for institutions with 100,000 or more entries. Crossing the threshold means correcting and resubmitting the entire data set.
Serious or repeated violations carry heavier consequences. In one enforcement action, the CFPB ordered Freedom Mortgage Corporation to pay a $3.95 million civil money penalty for repeated HMDA data errors. The company was also required to establish a HMDA compliance subcommittee, retain a third-party auditor, conduct quarterly transaction testing for at least five years, and correct data for multiple prior filing years.
After submitting, an institution must keep a copy of the submitted LAR for at least three years. The same three-year window applies to the public notice pointing requesters to the modified data on the CFPB’s website. Regulation C sets the three-year clock on those two items; regulators expect institutions to keep the supporting compliance documentation — audit reports, training records, corrective-action logs — as part of the broader examination framework.