HMDA is the regulatory data backbone of fair lending oversight. Most mortgage lenders are required to collect and report detailed information on every loan application they receive, with the data made publicly available through the CFPB.
What HMDA collects
- Loan amount, type, purpose
- Borrower’s race, ethnicity, sex, age (self-reported, with handling for borrowers who decline to provide)
- Property location (census tract)
- Income
- Action taken (approved, denied, withdrawn, incomplete)
- If denied: reasons for denial
- Pricing data: rate spread, APR
Who must report
Most depository and non-depository mortgage lenders meeting volume thresholds. Specifically: depositories with $54M+ in assets that originated 100+ closed-end loans in each of the prior 2 years; non-depositories that originated 100+ loans annually. Exemptions exist for very small originators.
How HMDA data is used
Regulators (CFPB, OCC, FDIC, Federal Reserve, state regulators) use HMDA data to identify potential fair lending violations through statistical analysis. If a lender’s denial rates are significantly higher for protected classes than for white non-Hispanic applicants in the same loan profile, regulators may open a fair lending investigation. Researchers and journalists also use the public HMDA dataset to investigate lending patterns by community, race, and geography.
