HMDA reporting requires a covered lender to collect defined data on every dwelling-secured application, origination and purchase, assemble it into a loan application register, clear the errors the filing platform flags, and file annually with its federal supervisory agency.
What follows covers who files, where the register’s data originates, the annual and quarterly deadlines, the four edit categories every file is tested against, and how the filed data is read back.
What HMDA Reporting Covers
Regulation C implements the Home Mortgage Disclosure Act and sets the coverage tests. A depository institution files if:
- Its assets exceed the threshold published annually in the Federal Register
- It has an office in a metropolitan statistical area
- It originated at least 25 closed-end mortgage loans or 200 open-end lines of credit in each of the two preceding calendar years.
The closed-end threshold is 25 rather than 100 because of litigation. Per the CFPB, a federal court vacated that part of the 2020 rule on 23 September 2022, and the threshold reverted to the 2015 standard of 25 loans.
Reportable transactions are applications, originations and purchases of covered loans secured by a dwelling, whether or not the dwelling is the borrower’s residence. A business-purpose loan secured by a dwelling can be HMDA reportable.
The HMDA LAR and Where Its Data Comes From
The HMDA LAR carries more than 100 data fields per record, and no single team produces all of them. They arrive from four places.
- Applicant and demographic data originates at application
- Loan terms and pricing come from underwriting and closing
- Property and geography derive from the address and the appraisal
- Action taken, dates and identifiers come from the decision record
Submission Deadlines and the Quarterly Obligation
The annual filing window runs from 1 January to 1 March of the year after collection. When 1 March falls on a weekend, a submission made the following Monday is timely.
An institution that reported at least 60,000 covered loans and applications combined in the preceding calendar year files quarterly as well as annually, in force since 1 January 2020. Purchased loans are excluded from that count, so an active correspondent buyer can stay under the quarterly trigger while filing a large annual register.
The Four Edits Every LAR Is Tested Against
The filing platform applies four categories of edit, and the distinction between them decides how much work a flagged file needs. The table sets out what each HMDA reporting edit category checks and what the filer has to do about it.
| Edit category | What it checks | Level | Filer action |
|---|---|---|---|
| Syntactical | File format and that the data covers the correct filing year | File | Must be corrected |
| Validity | Whether each data field contains a valid value | Field | Must be corrected |
| Quality | Whether field entries and combinations match expected values | Field | Corrected or confirmed |
| Macro quality | Whether the register as a whole matches expected values | File | Corrected or confirmed |
Syntactical and validity edits have to be fixed. Quality and macro quality edits flag values that are unusual but possible, so the filer either corrects the record or confirms the value is accurate.
Confirming an edit without investigating it is how an error reaches the published data. The FFIEC examiner testing guidelines do allow narrow tolerances when errors are counted.
What Happens to Filed HMDA Data
The CFPB publishes modified loan-level data and the FFIEC publishes disclosure and aggregate reports, so the register becomes a public description of the institution’s lending.
Fair lending review starts from the HMDA file. Denial rates, pricing and geographic distribution are compared across applicant groups and against peer institutions drawn from the same published data.
Automating HMDA Data Quality Checks
In May 2026 we released an Ask Kaia HMDA Compliance Testing Agent. Through this agent, a compliance team uploads its loan application register and the related loan documents, defines a testing scope, and receives audit reports on a loan-by-loan basis.
Frequently Asked Questions
Which loans are HMDA reportable?
Applications, originations and purchases of closed-end mortgage loans and open-end lines of credit secured by a dwelling are HMDA reportable, subject to the exclusions in Regulation C. Reportability turns on the dwelling security, so purpose alone does not settle it. Regulation C also excludes certain transactions outright, including temporary financing and loans made in a fiduciary capacity.
When is HMDA reporting required?
An institution files if it meets an institutional coverage test and originated at least 25 closed-end mortgage loans or 200 open-end lines of credit in each of the two preceding calendar years. Depositories also have to exceed the annually published asset-size threshold and have an office in a metropolitan statistical area. The annual submission is due by 1 March.
What happens if a HMDA file has errors?
Syntactical and validity edits must be corrected before the platform accepts the file. Quality and macro quality edits must be either corrected or confirmed as accurate. Errors that survive submission become part of the published data. Under the FFIEC HMDA Examiner Transaction Testing Guidelines, an examiner who finds 3 errors in a single data field in a sample from a register of up to 500 entries, or 4 errors for a larger register, directs the institution to correct that field and resubmit.
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