HMDA Getting It Right: A Guide for Compliance Teams
Reglith Editorial Team · October 2026
The HMDA getting it right guide is, in practice, the body of Regulation C (12 CFR Part 1003) requirements and Consumer Financial Protection Bureau (CFPB) guidance that governs how mortgage lenders collect, validate and submit Home Mortgage Disclosure Act data. It matters to any institution required to report, from depositories to non-depository lenders and servicers. Getting data right means treating collection, validation and submission as three distinct workflows rather than one annual event.
What does the HMDA getting it right guide cover?
The scope is Regulation C, which implements the Home Mortgage Disclosure Act and sets out what data covered institutions must collect, record and report. The CFPB publishes the rule text, the filing instructions and the technical specifications that define the file format, the permissible values for each data field and the edit checks applied before acceptance.
The audience is mortgage lenders, servicers and depository institutions that meet the coverage tests in Regulation C. Coverage depends on factors such as institution type, asset size, location and whether the institution originated covered loans in a prior year; those thresholds are adjusted annually, so the rule text and the current CFPB filing instructions control.
It helps to separate three stages. Collection happens at application and throughout the loan file. Validation happens against the CFPB's edit checks before submission. Submission is the annual filing itself. A failure in any stage typically surfaces as a runtime error or a resubmission obligation.
A broader treatment of reportable loan criteria and file structure is in HMDA Reporting: The Complete Guide for Mortgage Lenders.
Which loans are reportable under HMDA?
A reportable loan is generally a covered loan under Regulation C: a closed-end mortgage loan or an open-end line of credit secured by a dwelling, subject to the rule's exclusions. Both first liens and subordinate liens can be covered, which is why home equity lines of credit and second mortgages often appear in the data even when the institution treats them as a separate product line.
Business-purpose loans are commonly excluded when the purpose is commercial, but the analysis depends on the facts and the rule's definitions rather than on internal product labels. Temporary financing, certain agricultural loans and other categories may also fall outside coverage.
Small creditor and small servicer status can affect which loans an institution reports and, in some cases, whether an institution is covered at all. Those asset and loan-count thresholds are adjusted annually, so a figure that was accurate in one filing year may not be accurate in the next.
| Scenario | Typically reportable | Notes |
|---|---|---|
| Closed-end first lien | Yes, if covered | Core reporting population |
| Closed-end subordinate lien | Often yes | Depends on purpose and exclusions |
| HELOC | Often yes | Open-end lines can be covered |
| Business-purpose loan | Often no | Depends on the rule's definitions |
What demographic data must be collected and reported?
The regulation requires collection of three demographic fields for the applicant: ethnicity, race and sex. The collection process centers on applicant self-identification. The institution provides the collection form and the applicant chooses whether to provide the information.
When an applicant declines to provide the information in a face-to-face application, the rule permits a visual observation fallback under defined circumstances, and the institution records that basis. The fallback is not a general substitute for self-identification, and it does not apply to every application channel.
For joint applications, the regulation focuses reporting on the primary applicant's demographic data rather than aggregating both applicants. Compliance teams should confirm which applicant is treated as primary under the rule and reflect that consistently in the loan file.
Underlying fair lending considerations around demographic data and disparate impact analysis are covered in Fair Lending Compliance: The Complete Guide for Mortgage Lenders.
How do you assign the correct HMDA action code?
Action codes describe the institution's action on an application. Common values include an application received, an application approved but not accepted, a loan originated, an application denied, an application withdrawn and a file closed for incompleteness. Each code has a defined meaning in the rule and the filing instructions.
The timing matters: a code is assigned based on the action taken within the reporting year, not on when the file is finally closed for administrative purposes. A file that sits open at year-end can require a different code than one denied during the year.
Edge cases drive most errors. Withdrawn applications, incomplete files, counteroffers and applications that never reach a credit decision each map to specific codes, and the mapping depends on the facts in the file. A dedicated walkthrough of these scenarios is in the HMDA action codes resource on this site.
What are the key data validation rules?
The CFPB publishes data validation rules, often described as edit checks, that a submission must pass. These checks operate on the file before and during submission and flag errors such as missing required fields, values outside the permissible set, inconsistent loan amounts, and dates that do not align with the reported action.
The practical work is mapping the loan origination system's field values to the regulation's permissible values and running the checks internally before the filing window opens. Institutions that wait until submission to run validation often find systemic errors that require corrections at scale.
A list of specific validation checks and the error messages they produce is maintained in the HMDA data validation resource on this site.
When and how do you submit HMDA data?
HMDA data is submitted annually, generally by March 1 for the prior calendar year, using the CFPB's filing platform. The platform applies the edit checks and returns errors for correction before the submission is accepted.
After submission, institutions can correct errors. Certain corrections fall within a defined window after the submission, and the filing instructions describe which changes require an amendment versus a resubmission. The distinction matters for recordkeeping and for how the correction is reflected in the public data.
A step-by-step procedure for amending previously filed data is set out in the HMDA resubmission requirements resource on this site. Institutions that rely on a third-party filing agent should still confirm the deadline and the correction window directly in the CFPB filing instructions.
How does HMDA interact with other mortgage regulations?
HMDA does not stand alone. Loan terms and pricing reported under Regulation Z (12 CFR 1026) and disclosed through the TILA-RESPA Integrated Disclosures (TRID) often need to reconcile with the corresponding HMDA fields, and mismatches between disclosure data and reported data can signal a broader data integrity problem. A fuller treatment of those reconciliation points is in TRID Compliance: The Complete Guide to TILA-RESPA Integrated Disclosures.
Applicant identification data collected under Bank Secrecy Act and anti-money-laundering programs can overlap with HMDA demographic fields, though the collection purposes and rules differ. Institutions typically coordinate the two workflows so that neither distorts the other.
HMDA data also feeds into secondary market and agency reporting, including Ginnie Mae mortgage-backed securities programs, where loan-level characteristics must be consistent with the data reported under Regulation C. The Ginnie Mae MBS guide sets out the agency's own reporting expectations.
A broader map of how these rules fit together is in The Complete Guide to Federal Mortgage Compliance Regulations.
How do you monitor regulatory changes for HMDA?
Rule changes to Regulation C are published in the Federal Register, and proposed rules, final rules and technical corrections each carry their own comment periods and effective dates. The Federal Register notice and the corresponding eCFR entry are the authoritative sources for the current rule text.
A practical monitoring routine tracks the Federal Register for HMDA-related notices, checks the CFPB's filing instructions each year before the submission window, and updates the compliance calendar when a change takes effect. A walkthrough of that process is in the how-to-read the Federal Register guide on this site.
Complaints and consumer inquiries that touch on HMDA data often arrive through channels governed by Regulation X (12 CFR 1024), so error resolution procedures should be reviewed alongside the HMDA filing calendar rather than treated as a separate workstream. Institutions that hold state licenses may also need to coordinate with state examination requests; a starting point is Mortgage Licensing and NMLS: The Complete Compliance Guide, and state-specific requirements sit in State mortgage licensing requirements and State rules by topic.
Reglith tracks federal, agency and state regulatory changes in one feed, summarized and tagged for mortgage compliance teams. Reglith regulatory updates
Frequently asked questions
What is the purpose of HMDA getting it right?
The purpose is accurate, complete and timely reporting of Home Mortgage Disclosure Act data under Regulation C. Accurate data supports fair lending analysis, public transparency and supervisory review. The operational goal is to collect the required fields at application, validate them against the CFPB's edit checks before submission, and file by the annual deadline.
What is the 3 7 3 rule for a mortgage?
There is no such rule in federal mortgage regulation. The phrase is not a defined term in Regulation Z, Regulation C or Regulation X, and it does not appear in the CFPB's rule text. Compliance teams should not treat it as a citation; verify any rule reference against the regulation itself or the Federal Register notice that adopted it.
What are the 6 TRID requirements?
TRID requirements are set out in Regulation Z and Regulation X rather than as a numbered list of six. They include the Loan Estimate, the Closing Disclosure, the timing rules for delivery, tolerances for changed circumstances, the good-faith analysis of fees, and recordkeeping. For the specific obligations, rely on the rule text and the CFPB's TRID guidance.
What 3 demographic information items must a bank collect and report for HMDA purposes?
The three items are ethnicity, race and sex. The institution provides applicants the opportunity to self-identify, and the primary applicant's responses are reported for joint applications. When an applicant declines in a face-to-face setting, a visual observation fallback can apply in defined circumstances.