What Is Home Mortgage Disclosure Act (HMDA)?
The Home Mortgage Disclosure Act (12 U.S.C. § 2801) requires financial institutions to collect and publicly disclose data on mortgage applications, originations, and purchases. HMDA data reveals patterns in mortgage lending by race, ethnicity, income, and geography — enabling regulators, researchers, and the public to detect lending disparities, discriminatory practices, and geographic gaps in credit access.
Key Facts
- HMDA was enacted in 1975 following evidence of widespread redlining — the systematic denial of mortgage credit to residents of minority and low-income neighborhoods — and has been amended most recently by the Dodd-Frank Act, which transferred rulemaking to the CFPB and substantially expanded required data fields
- The FFIEC (Federal Financial Institutions Examination Council) publishes HMDA data annually at ffiec.gov/hmda — the 2023 dataset covers approximately 10 million applications from over 5,200 reporting institutions, with 99 data fields per record
- HMDA data consistently reveals a persistent denial rate gap: Black applicants are denied conventional mortgages at roughly 2x the rate of similarly situated white applicants — a gap that persists even after controlling for credit score, income, and loan-to-value ratio in academic research
- Regulation C (12 CFR Part 1003), the CFPB's implementing regulation for HMDA, was substantially revised in 2018 to add 25 new required data fields including credit score, debt-to-income ratio, automated underwriting system results, and property type — making modern HMDA data far more detailed than the original reporting requirements
- HMDA data is one of two key federal tools for identifying fair lending violations — the other is ECOA (Equal Credit Opportunity Act, 15 U.S.C. § 1691). When HMDA data shows disparate denial rates, regulators use it to trigger fair lending examinations and enforcement actions against lenders
Live Data
Why HMDA Exists: The Redlining Problem
In the decades following World War II, federal housing policy and private lending practices systematically denied mortgage credit to African American families and to residents of racially mixed neighborhoods. The Home Owners' Loan Corporation (HOLC) color-coded neighborhood maps from the 1930s — literally drawing red lines around minority neighborhoods — became the blueprint for private lenders to deny mortgages regardless of individual creditworthiness. The result was a near-complete exclusion of Black Americans from the postwar homeownership boom that built the white middle class.
By the 1970s, community advocacy groups and journalists had documented that major banks simply refused to lend in certain zip codes. The problem was that without data, it was nearly impossible to prove. A bank could always claim its decisions were based on individual creditworthiness. HMDA was Congress's response: force lenders to reveal where they are and are not lending, and let the data speak.
What HMDA Requires Lenders to Report
Under current Regulation C, covered lenders must report detailed data on each mortgage application they receive, including:
- Applicant demographics: Race, ethnicity, sex, and age — collected through the same government monitoring information form used for FHA and conventional loans
- Loan characteristics: Loan type (conventional, FHA, VA, USDA), loan purpose (purchase, refinance, home improvement), property type, occupancy, loan amount, and whether the lender sold the loan on the secondary market
- Underwriting data (added in 2018): Credit score, debt-to-income ratio, combined loan-to-value ratio, automated underwriting system results, and total loan costs
- Outcome: Whether the application was originated, denied, withdrawn, or incomplete — and if denied, the primary denial reason
- Pricing: The interest rate, rate spread (difference from average prime offer rate), and total origination charges
This is reported annually to the CFPB, which publishes it in a public database (ffiec.gov/hmda). Any researcher, journalist, regulator, or community organization can download and analyze the complete dataset.
What HMDA Data Reveals About the Housing Market
HMDA data is the primary empirical basis for understanding mortgage lending disparities. Recent years' data consistently shows:
- Denial rate gaps: Black applicants face denial rates approximately 2x higher than white applicants for conventional loans, even after controlling for observable creditworthiness factors
- FHA concentration: Black and Hispanic borrowers disproportionately use FHA loans, which require lower credit scores and down payments — but also carry higher mortgage insurance premiums. FHA's higher delinquency rate (11.52% vs. 2.89% conventional) reflects both economic circumstances and the population channeled into FHA products
- Geographic gaps: HMDA data maps areas where few loans are made relative to population — revealing which neighborhoods remain effectively excluded from conventional credit access
- Pricing disparities: Analysis of HMDA rate spread data reveals that minority borrowers received higher-rate loans more frequently than similarly qualified white borrowers during the subprime boom
How HMDA Connects to Enforcement
HMDA data is a screening tool, not a finding of discrimination. When HMDA data shows a lender has a statistically significant disparity — denying Black applicants at rates far higher than white applicants with similar profiles — regulators may conduct a fair lending examination. The exam reviews individual loan files and underwriting decisions to determine if the disparity reflects genuine creditworthiness differences or discriminatory treatment.
If an examination confirms discrimination, regulators can pursue enforcement under ECOA (Equal Credit Opportunity Act) or the Fair Housing Act. The CFPB, DOJ, OCC, FDIC, and FHFA all use HMDA data in their supervisory and enforcement programs.
Notable enforcement actions triggered by HMDA data include the DOJ's $335 million settlement with Countrywide Financial (2011) for steering Black and Hispanic borrowers into higher-cost loans, and numerous smaller community bank cases where geographic analysis of HMDA data revealed failure to serve minority neighborhoods.
HMDA's Limitations
HMDA data has important limitations that affect how it should be interpreted:
- It shows outcomes — approvals and denials — but cannot conclusively establish whether disparities reflect discrimination, differences in unobserved creditworthiness factors, or both
- Coverage thresholds exclude smaller lenders below certain loan volume minimums, creating gaps in rural area data
- Self-reported race/ethnicity data may be incomplete when applicants decline to provide it, particularly for online applications
- It does not capture predatory lending within approvals — an applicant might be approved but steered into a more expensive product than their credit profile warranted
State-by-State Variations
HMDA is a federal disclosure law — it does not vary by state in its requirements. However, state fair lending laws determine how HMDA data is used for enforcement, and some states have enacted their own mortgage data reporting requirements.
| State | Key Difference |
|---|---|
| New York | New York Banking Law § 296-a and the Community Reinvestment Act (CRA) framework — NYS DFS uses HMDA data in conjunction with CRA evaluations for state-chartered banks. New York also requires community benefits agreements with banks seeking merger approval |
| California | California's Housing Financial Discrimination Act of 1977 (Holden Act, Health & Safety Code § 35800) was the state-level predecessor to HMDA, banning redlining in California before federal law was strengthened. The DFPI uses HMDA data alongside state fair lending law in its examinations |
| Illinois | Illinois Fairness in Lending Act (815 ILCS 120/) requires lenders to make their HMDA data available in community offices and mandates correction of significant disparities identified in HMDA analysis — going beyond federal disclosure to require remedial action |
| Massachusetts | Massachusetts has a strong state CRA applying to state-chartered banks and credit unions — the Division of Banks uses HMDA data in CRA evaluations and has a community reinvestment agreement framework that incorporates HMDA disparity analysis |
| Texas | Texas does not have a state-level fair lending law beyond federal ECOA and Fair Housing Act coverage — HMDA enforcement in Texas relies primarily on federal regulators (CFPB, OCC, FDIC). The state's large geographic spread creates significant HMDA data gaps in rural areas |
Frequently Asked Questions
Where can I access HMDA data?
HMDA data is publicly available at ffiec.gov/hmda and through the CFPB's HMDA Data Browser at cfpb.gov/data-research/hmda. You can filter by institution, geography, loan type, race, and year. The full dataset is downloadable as CSV files. The FFIEC also publishes aggregated statistical reports for every metropolitan area annually.
Does HMDA data prove that my lender discriminated against me?
No — HMDA data shows aggregate patterns, not individual decisions. If HMDA data shows your lender has high denial rates for minority applicants, that is a signal for further investigation, not proof of discrimination in your case. Individual lending discrimination claims require showing that similarly qualified applicants of a different race or ethnicity were treated differently.
Which lenders have to report HMDA data?
Covered institutions include banks, credit unions, savings institutions, and mortgage companies that meet certain thresholds: they must be federally insured or regulated, have a home or branch office in a metropolitan statistical area, and have originated at least 25 closed-end mortgage loans or 100 open-end lines of credit in each of the two preceding calendar years.
How is HMDA different from the Community Reinvestment Act (CRA)?
HMDA is a disclosure law — it requires data reporting but does not require any specific lending behavior. CRA is a performance law — it requires federally insured depository institutions to actively serve the credit needs of the communities where they take deposits, including low- and moderate-income areas. Regulators use HMDA data as evidence in CRA examinations, but they are separate legal frameworks.
Can I use HMDA data to challenge my mortgage denial?
HMDA data can support a fair lending complaint if it shows your lender has a pattern of denying applications from members of your demographic group. File a complaint with the CFPB, FHFA, or your state banking regulator, citing the HMDA data. However, your individual claim also requires showing your application was comparable to approved applications from differently situated borrowers.