What Is HMDA Data? The Home Mortgage Disclosure Act Explained

The Home Mortgage Disclosure Act requires mortgage lenders to publicly disclose data on every application they receive. It's the federal government's primary tool for detecting lending discrimination — and a powerful resource for anyone evaluating a bank's lending practices.

Why HMDA was created

Congress passed HMDA in 1975 following decades of documented mortgage lending discrimination — particularly redlining, the practice of systematically denying loans in minority or low-income neighborhoods. By requiring lenders to disclose application-level data, the law created a public record that community groups, journalists, and regulators could use to identify patterns of discrimination.

The law has been amended several times, most significantly by the Dodd-Frank Act in 2010, which expanded the data fields lenders must report and transferred oversight to the Consumer Financial Protection Bureau (CFPB).

What HMDA data includes

For every mortgage application, lenders must report:

• Census tract of the property
• Loan type (conventional, FHA, VA, USDA)
• Loan purpose (purchase, refinance, home improvement)
• Applicant race, ethnicity, sex, and age
• Applicant income
• Loan amount
• Action taken (originated, denied, withdrawn, incomplete)
• Denial reason (if denied)
• Interest rate spread and total loan costs (since 2018)

The full dataset contains tens of millions of records annually and is available for download from the CFPB. BankScorer processes this data and computes origination rates and denial rates for each lender, making it easy to compare across institutions without downloading raw files.

Who must file HMDA reports

Most banks, credit unions, and non-bank mortgage companies that originate above a threshold volume must file. The current thresholds are 25 closed-end mortgage loans or 100 open-end lines of credit in each of the two preceding years, and the institution must have an office in an MSA (Metropolitan Statistical Area).

Smaller lenders below the threshold are exempt — which means HMDA data doesn't capture the full picture of mortgage lending in rural areas where smaller institutions dominate.

What HMDA data can and can't tell you

HMDA can tell you where a lender is making loans geographically, what percentage of applications it denies, and whether denial rates differ by applicant race or ethnicity. These patterns are what regulators and fair lending advocates look for when investigating potential discrimination.

HMDA can't tell you whether a specific denial was discriminatory — a higher denial rate for a demographic group may reflect differences in creditworthiness, not bias. HMDA provides the starting point for an investigation, not the conclusion.

How to use HMDA data to evaluate a bank

On BankScorer, every bank profile includes a Mortgage Lending section showing:

• Total mortgage applications and originations per year (2018–2024)
• Origination rate and denial rate
• How the denial rate compares to other banks in the same state

The Mortgage Lenders page lets you browse and sort all lenders by origination volume, denial rate, and year. You can also compare HMDA data alongside a bank's CRA rating — the two are related: regulators consider HMDA data when assigning CRA ratings.