HMDA Reporting Thresholds: Who Must Report and What Changed

This is the coverage companion to two other posts in this series. Our guide to HMDA reporting requirements covers what the register contains and how the data is used; the piece on data scrubbing covers getting the register clean. This one answers a narrower question that a surprising number of institutions get wrong: are we a HMDA reporter this year, and for which products?

Why This Is a Real Question

Institutions treat coverage as a settled fact. It is not — it is a determination that can change annually without any change in strategy, because the criteria are measured on rolling prior-year data and the asset threshold moves with inflation.

Two failure modes, both genuine:

Reporting when not required. An institution whose volume fell below a threshold continues collecting and reporting, incurring cost and — more consequentially — publishing data that invites analysis it had no obligation to expose.

Not reporting when required. Volume grew through a threshold, nobody reassessed, and the institution discovers the omission at examination. Because HMDA data is annual and public, a missed year is conspicuous.

The Three Coverage Questions

Coverage requires yes to all three, assessed in order.

Is the institution covered?

For a depository institution, the criteria generally combine:

• An asset threshold, adjusted annually for inflation
• A home or branch office located in a metropolitan statistical area as of the preceding December 31
• Federal insurance or regulation, or a covered loan insured, guaranteed, or supplemented by a federal agency, or intended for sale to Fannie Mae or Freddie Mac
• At least one covered home purchase loan or refinancing secured by a first lien on a one-to-four unit dwelling originated in the preceding calendar year

Non-depository institutions have their own criteria.

The MSA condition catches institutions out. An institution wholly outside any metropolitan statistical area may fall outside coverage entirely, and a single branch opening inside one can change the answer.

Is the loan volume threshold met?

Separate thresholds apply to closed-end mortgage loans and to open-end lines of credit, each measured over each of the two preceding calendar years.

Two features matter operationally. Because each threshold is separate, an institution can be a reporter for closed-end loans and not for open-end lines, or the reverse. And because the test looks at each of two years rather than an average, a single year above the threshold does not create coverage and a single year below does not remove it.

NOTE TO EDITOR: The closed-end threshold in particular has a litigation history — a 2020 rule raised it, and that increase was vacated in 2022 litigation, restoring the earlier figure. Confirm the current number before publishing anything specific.

Is the transaction covered?

Covered transactions are generally closed-end mortgage loans and open-end lines of credit secured by a dwelling, including home purchase, refinancing, and home improvement, plus applications and purchased loans. Several transaction types are excluded, and the exclusions are specific rather than intuitive.

Partial Exemptions

Legislation created partial exemptions relieving lower-volume institutions of reporting certain data points while still requiring the register.

The practical shape: an institution below the applicable volume thresholds for closed-end or open-end transactions may omit a defined set of data points for that transaction type, while continuing to report the remainder. Exemption eligibility is determined separately for closed-end and open-end lending.

Three points institutions get wrong:

A partial exemption is not an exemption. The register is still filed. Only certain fields are relieved.

Eligibility is per transaction type, so an institution may be exempt for open-end and not for closed-end.

Collecting the data anyway is a choice with consequences. Some institutions collect exempt fields for internal fair lending analysis, which is defensible — but if collected and reported, the data is public. Deciding deliberately, and documenting the decision, is better than defaulting either way.

Quarterly Filing

Institutions exceeding a high volume threshold file quarterly in addition to the annual submission. Most community banks are well below it, but an institution growing through it needs the operational cadence in place before the first quarterly deadline rather than after.

Making Reassessment Routine

The whole problem is solved by putting the determination on the calendar with an owner.

Every January, document the coverage determination for the new year: asset size against the current threshold, MSA office status as of December 31, prior-year originations, and closed-end and open-end volumes for each of the two preceding years. Record the conclusion, the data supporting it, and the date.

Reassess on trigger as well: a branch opening or closing, a merger or acquisition, entry into or exit from a product line, or crossing the asset threshold mid-year.

Watch the direction of travel. An institution approaching a threshold from below should prepare before it crosses, because becoming a reporter requires data capture at origination that cannot be reconstructed retroactively. An institution that discovers in January that it became a reporter for the prior year has a problem no amount of scrubbing fixes.

Document a negative determination too. "Not a reporter" with the supporting data is a defensible position; "we don't report" with no analysis is indistinguishable from never having considered it.

Structured coverage is available through our HMDA compliance training and the HMDA — Home Mortgage Disclosure Act course.

Preparing to Become a Reporter

For an institution whose volume is trending toward coverage, the work starts a year before the obligation.

Data capture is the long pole. The register requires fields that must be collected at application — government monitoring information under specific collection rules, property details, pricing components, and underwriting inputs. None of it can be reconstructed after the fact, which means the origination system, the application forms, and the staff taking applications all have to change before the reporting year begins, not before the filing deadline.

Geocoding has to work at entry. Address normalization and census tract assignment at the point of capture prevents the largest category of HMDA error, and retrofitting it later means correcting a year of records.

Someone must own it. Coverage determination, edit resolution, submission, and the fair lending analysis are compliance responsibilities; field-level accuracy is origination's. Both need named individuals before the first reportable application arrives.

Assume the data will be analyzed. The point of HMDA is transparency, and becoming a reporter means the institution's lending patterns become publicly comparable to its peers'. Any institution about to cross the threshold should run the analysis on its own historical lending first, so that management learns what the data shows from its own compliance function rather than from a community group's letter.

That last point is the one most often skipped, and it is the difference between an institution that becomes a reporter and one that becomes a reporter with an explanation ready.

Ceasing to Be a Reporter

The reverse transition gets almost no attention and carries its own traps.

An institution whose volume falls below the applicable threshold for the required measurement period is no longer a reporter for that transaction type. Three things follow, and none is automatic.

Stop collecting, deliberately. Government monitoring information is collected under specific rules about how it may be requested, and continuing to collect it once the obligation ends is a choice. Some institutions continue voluntarily for internal fair lending analysis, which is legitimate — but the collection should be a documented decision, and staff should understand that the framing to applicants is different when it is not required.

File for the final covered year. Coverage is determined by the measurement period, not by the current year's activity, so an institution that drops below the threshold still files for the year in which it was covered. The submission deadline arrives after the institution has stopped thinking about HMDA, which is exactly when it gets missed.

Retain the records. Recordkeeping obligations attach to the years the institution was covered and do not evaporate with coverage. The register, the workpapers, and the supporting documentation all remain subject to the applicable retention period.

There is also a strategic consideration worth raising with management. An institution that exits HMDA reporting loses the annual, externally comparable view of its own lending distribution — which is, incidentally, the data most useful for fair lending self-monitoring and for CRA analysis. Several institutions that dropped below the threshold have continued the internal analysis for exactly that reason, using their own loan data rather than a filed register.

The practical recommendation: treat the exit from coverage as deliberately as the entry, with a documented determination, an explicit decision about voluntary collection, a calendared final filing, and a retention plan. Institutions that simply stop are the ones that miss the last submission.

A final note on why the thresholds have moved as much as they have. HMDA coverage sits at a genuine policy tension: raising thresholds reduces burden on small lenders, and it simultaneously removes those lenders' lending patterns from the public record used to detect discrimination. That is why threshold changes attract both rulemaking and litigation, and why an institution should not assume any particular figure is settled. The practical implication for a compliance calendar is modest but real — treat the coverage criteria as a value to look up each January rather than a constant to remember, and note the date of whatever you relied on.

One operational detail worth adding for institutions that acquire loans rather than originate them. Purchased covered loans are reportable, and an institution that buys a portfolio can find itself with reporting obligations attached to transactions it never touched at origination. The data must still be reported, which means it must have been obtained in the acquisition — a due diligence item that is easy to omit and impossible to fix afterward. Any loan purchase agreement should address delivery of the HMDA data elements for covered loans, and the coverage determination should account for purchased volume alongside originations.

Frequently Asked Questions

Who has to report HMDA data?

Coverage requires meeting institutional criteria — an asset threshold adjusted annually, a home or branch office in a metropolitan statistical area, federal insurance or regulation, and at least one qualifying origination in the prior year — and separately meeting loan volume thresholds measured for closed-end and open-end lending over each of the two preceding years. All three levels must be satisfied.

Can an institution be a HMDA reporter for one product and not another?

Yes. The closed-end mortgage and open-end line of credit thresholds are separate and measured independently, so an institution can be a reporter for one transaction type and not the other. Partial exemption eligibility is likewise determined separately by transaction type.

How often should coverage be reassessed?

Annually, and on trigger. The criteria are measured on rolling prior-year data and the asset threshold moves with inflation, so coverage can change without any change in strategy. Branch openings or closings, mergers, and entering or exiting a product line should each prompt a fresh determination.

What is a HMDA partial exemption?

Relief from reporting certain data points, available to institutions below applicable volume thresholds — but not relief from filing the register. Only specified fields are relieved, eligibility is determined separately for closed-end and open-end lending, and an institution that chooses to collect and report exempt fields anyway makes that data public.

What happens if an institution missed a year of HMDA reporting?

It is conspicuous, because HMDA data is annual and public. More practically, the required fields must be collected at application and cannot be reconstructed afterward, so a missed reporting year cannot be cured by scrubbing — which is why an institution approaching a threshold should prepare before crossing it rather than after.

Should a negative coverage determination be documented?

Yes. "Not a reporter," supported by the asset figure, office locations, and two years of volume data, is a defensible position. Simply not reporting, with no recorded analysis, is indistinguishable at examination from never having considered the question.