Home Mortgage Disclosure Act (HMDA)

Home Mortgage Disclosure Act (HMDA)

Key takeaways

• HMDA (enacted 1975) requires many mortgage lenders to collect and report standardized data about mortgage applications, originations, and denials.
• The law promotes transparency to detect discriminatory or predatory lending and to ensure lenders serve community credit needs.
• Data reported under HMDA supports fair-lending enforcement, community investment planning, and public research; records are publicly accessible (with privacy protections).

Overview

The Home Mortgage Disclosure Act (HMDA) is a federal law that requires certain mortgage lenders to compile and submit data about mortgage applications, originations, purchases, and denials. Regulators, community groups, researchers, and the public use HMDA data to monitor lending patterns, detect possible discrimination, and guide community investment.

History and legal authority

• Enacted by Congress in 1975 to address discriminatory lending and improve market transparency.
• Regulation C implemented HMDA’s requirements; it was created by the Federal Reserve and is now maintained and enforced by the Consumer Financial Protection Bureau (CFPB) following the Dodd‑Frank Act.
• The statutory text appears in Title 12, Chapter 29 of the U.S. Code. The Federal Financial Institutions Examination Council (FFIEC) has also played a role in facilitating public access to HMDA data.

What lenders must report

HMDA reporting typically includes:
* Loan/application details for home-purchase loans, home-improvement loans, and refinancings (applications, originations, purchases).
Applicant demographics collected for monitoring purposes, such as race, ethnicity, sex, and income (collected with privacy protections and anonymized in public release).
Action taken on an application (approved, denied, withdrawn, incomplete), and the reason(s) for denial.
* Loan amount, purpose, and information on government‑sponsored loans (e.g., FHA, VA, USDA/Rural Housing Service, Farm Service Agency).

Not all lenders are subject to HMDA; coverage is determined by institution type, asset size, and volume of mortgage activity.

Reporting thresholds and timing

• Lenders file HMDA data annually. Calendar‑year data must generally be submitted by March 1 of the following year.
• In 2020 the CFPB raised the reporting threshold for closed‑end mortgage loans from 25 to 100 loans (effective July 1, 2020), changing which smaller lenders must report.
• As an example of scale, thousands of institutions report HMDA data each year (recent filings have included millions of loan originations).

Purpose and uses

HMDA’s goals and practical uses include:
* Detecting and documenting potentially discriminatory or predatory lending patterns for enforcement under laws such as the Equal Credit Opportunity Act, the Fair Housing Act, and the Community Reinvestment Act.
Informing policymakers, community organizations, and investors about geographic and demographic lending trends.
Guiding community development and public investment by highlighting areas underserved by mortgage credit.
* Enabling public accountability—HMDA data is published in a manner intended to protect applicants’ privacy while allowing aggregate and geographic analysis.

Public access and compliance

• HMDA data are publicly available—many institutions must display information in branch lobbies about how to request their HMDA statistics, and the CFPB maintains a public data repository.
• Regulation C specifies data collection, reporting formats, and retention requirements; CFPB oversight and examinations ensure compliance.

Quick FAQs

Q: How often must lenders report HMDA data?
A: Annually; calendar‑year data are typically due by March 1 of the following year.

Q: What demographic information is collected?
A: Lenders collect sex, race, ethnicity, and applicant income for monitoring purposes; public releases protect individual privacy.

Q: Who enforces HMDA?
A: The CFPB enforces HMDA through Regulation C; other federal and state agencies may use HMDA data in examinations and enforcement.

Conclusion

HMDA is a foundational transparency tool in the U.S. mortgage market. By standardizing and publishing lending data, it helps regulators, community groups, and the public identify lending disparities, track market trends, and promote fair access to mortgage credit.

Sources

CFPB (Regulation C / HMDA), 12 U.S.C. Chapter 29 (Home Mortgage Disclosure), FFIEC guidance, FDIC materials.