What Types of Loans Are HMDA Reportable? Purposes, Dwellings, Thresholds

A loan is HMDA reportable when it is either a closed-end mortgage loan or an open-end line of credit, secured by a lien on a dwelling, and made for a covered purpose — home purchase, home improvement, or refinancing — unless it falls into a specific carve-out. That is the whole test, and understanding what loans are HMDA reportable comes down to walking each transaction through it. The trap for most institutions is not the obvious residential mortgage. It is the business-purpose loan, the manufactured-home loan, the reverse mortgage, and the construction loan that quietly meet the definition.

The Two Loan Types That Can Be Reportable

Every HMDA-reportable transaction is one of two things. A closed-end mortgage loan is an extension of credit that creates a fixed debt obligation secured by a dwelling lien. The borrower receives the loan amount at closing and repays it over a set term. A 30-year fixed-rate mortgage is the standard example.

An open-end line of credit is a revolving credit arrangement, also secured by a dwelling lien, that lets the borrower draw, repay, and draw again up to a limit. A home equity line of credit is the typical example. The line must meet the definition of open-end credit under Regulation Z, meaning the lender contemplates repeated transactions and credit becomes available again as the balance is repaid.¹

If a transaction is neither of these, it is not HMDA reportable, full stop.

Covered Purposes

Being a dwelling-secured loan is not enough. The loan also has to serve a covered purpose. Regulation C recognizes five purpose codes:

Home purchase — a loan used to buy a dwelling, including a condo unit, manufactured home, or investment property.
Home improvement — a loan used to repair, remodel, or upgrade a dwelling or the real property it sits on.
Refinancing — a new dwelling-secured obligation that pays off and replaces an existing one held by the same borrower.
Cash-out refinancing — a refinancing where the new loan amount exceeds the payoff of the existing obligation, with the borrower receiving the difference in cash.
Other purpose — a dwelling-secured loan that does not fit any of the above but is still a covered transaction.

Institutions assign separate purpose codes for standard refinancings and cash-out refinancings.²

Preapproval requests for home purchase loans are also reportable, but only in three situations: the request is denied, the request is approved but the applicant does not accept, or the request results in an origination. Preapproval requests that are withdrawn or left incomplete do not trigger a reporting obligation.³

What Counts as a Dwelling

The definition of “dwelling” under HMDA is broader than most people expect. A dwelling is any residential structure. It does not need to be attached to real property, and it does not need to serve as the borrower’s principal residence.⁴ Qualifying structures include:

Detached single-family homes
Individual condominium and cooperative units
Manufactured and other factory-built homes
Multifamily apartment buildings
Mixed-use properties containing residential units

Manufactured homes deserve extra attention. A loan secured by a manufactured home is reportable even if the home sits on rented land and the loan does not include the land. Institutions must indicate whether the loan is secured by the manufactured home and land together or by the home alone, and this distinction applies even when state law treats the manufactured home as real property.⁴

The property has to be located in a U.S. state, the District of Columbia, or Puerto Rico.⁵

Business-Purpose Loans That Still Get Reported

A common misconception is that business or commercial loans fall outside HMDA. They usually do, but there is one important exception: if a business-purpose loan also qualifies as a home purchase, home improvement, or refinancing, it is reportable. The business purpose does not shield it.

Transactions compliance teams frequently miss include:

A loan to an investor to buy a single-family rental property (home purchase, even though it’s an investment)
A line of credit to renovate a multifamily apartment building (home improvement)
A loan to a corporation to purchase a dwelling for employee housing (home purchase)
A refinancing of any of these existing dwelling-secured obligations

Even a loan to improve a medical office or daycare center can be reportable if the office is located inside a dwelling that is not a multifamily property.⁴ The test is always whether the transaction meets the definition of a covered purpose, regardless of who the borrower is or why they need the funds.

Purchased Loans, Assumptions, and Reverse Mortgages

HMDA is not limited to loans your institution originates. You also report covered loans that your institution purchases from another lender. The underlying transaction still has to be a closed-end mortgage loan or open-end line of credit secured by a dwelling. Several data fields work differently for purchased loans: demographic information about the borrower is optional, and fields like credit score, debt-to-income ratio, and rate spread are reported as “not applicable.”⁴

Assumptions are covered too. When your institution accepts a new borrower in place of the original obligor on an existing dwelling-secured loan through a written agreement, that assumption is an extension of credit under Regulation C. If the new borrower is assuming the loan to buy the property, the transaction is reported as a home purchase loan. Successor-in-interest transactions where an individual inherits a property and then assumes the existing debt also count.

Reverse mortgages are reportable. Institutions report the initial principal limit rather than a traditional loan amount, and some fields that apply to forward mortgages, like rate spread, are reported as “not applicable.”³

Loan modifications generally are not reportable. A modification that changes the terms of an existing obligation without satisfying and replacing it does not create a new debt obligation, so it falls outside the definition of a covered loan.

Loans That Are Excluded

Even a loan that clears the dwelling and covered-purpose tests may still be carved out of HMDA. The main exclusions:

Fiduciary transactions. Loans originated or purchased by the institution acting as a trustee or in another fiduciary capacity.⁶
Unimproved land. Loans secured only by vacant or unimproved property, unless the institution knows the borrower plans to build or place a dwelling on the land within two years.⁶
Temporary financing. Short-term loans designed to be replaced by permanent financing from any lender, including bridge loans and construction-only loans for homes being built for sale.
Pool purchases and servicing rights. Buying an interest in a pool of mortgage loans, such as a mortgage-backed security, or buying only the right to service loans.
Loans under $500. Any dwelling-secured transaction where the total amount is less than $500.⁷
Agricultural loans. Loans used primarily for agricultural purposes, including loans secured by a dwelling on a farm.⁷
Business-purpose loans that do not also qualify as a home purchase, home improvement, or refinancing.

The Construction Loan Trap

Construction lending is where exclusion questions get tricky. A standalone construction loan made to a builder who will sell the finished home before the loan matures is temporary financing and excluded. A construction-to-permanent loan that automatically converts to long-term financing after the build phase is not temporary financing, because it is not designed to be replaced by a separate loan. That transaction is reportable from the start.⁴

A loan to an investor to buy and renovate a property before flipping it is also not temporary financing. The investor intends to sell the property and pay off the loan from the sale proceeds, which is a different situation from a bridge loan that tides a borrower over until their permanent mortgage closes.

Volume Thresholds That Determine Whether You Report at All

An institution that meets the coverage criteria still only reports the loan categories where it hits the volume threshold. The two thresholds work independently, so a lender might report closed-end loans and not open-end lines, or the other way around:

Closed-end mortgage loans: report if your institution originated at least 25 closed-end mortgage loans in each of the two preceding calendar years.⁸
Open-end lines of credit: report if your institution originated at least 200 open-end lines of credit in each of the two preceding calendar years.⁹

The closed-end threshold of 25 reflects the original level set by the CFPB’s 2015 rule. The Bureau raised it to 100 in 2020, but a federal court vacated the higher threshold in 2022, reverting it to 25.⁸ Some older CFPB guidance materials still reference the 100-loan threshold, so verify you are working from current rules.

If a loan category falls below its threshold, the loans in that category are not reportable for your institution, even though they would be reportable at a larger lender. The dwelling-plus-purpose test decides whether a loan is the kind of loan HMDA covers; the volume thresholds decide whether your institution has to report it.

1
Consumer Financial Protection Bureau. 12 CFR Part 1026 – Truth in Lending (Regulation Z)
2
Consumer Financial Protection Bureau. Reportable HMDA Data – Regulatory and Reporting Overview Reference Chart
3
Consumer Financial Protection Bureau. 12 CFR Part 1003 (Regulation C) – 1003.4 Compilation of Reportable Data
4
Federal Financial Institutions Examination Council. A Guide to HMDA Reporting – Getting It Right (2024 Edition)
5
Federal Financial Institutions Examination Council. A Guide to HMDA Reporting – Getting It Right (2021 Edition)
6
Consumer Financial Protection Bureau. 12 CFR Part 1003 (Regulation C) – 1003.3 Exempt Institutions and Excluded and Partially Exempt Transactions
7
eCFR. 12 CFR Part 1003 – Home Mortgage Disclosure (Regulation C)
8
Consumer Financial Protection Bureau. Judicial Vacatur of Coverage Threshold for Closed-End Mortgage Loans
9
Federal Register. Home Mortgage Disclosure (Regulation C) Adjustment to Asset-Size Exemption Threshold