HMDA Training: What LAR Staff Need Before Filing Season

9/9/2026

HMDA errors are rarely made in February. They are made in May, at a kitchen table, when a loan officer takes an application by phone and skips the demographic questions. They are made in July, when a processor keys a property address that will never geocode. They are made in October, when an underwriter's denial reason does not match what went into the file. By the time the HMDA coordinator runs the edits in January, the data has been wrong for months, and fixing it means pulling files one at a time.

That is why HMDA training is not a one-person problem. The coordinator who submits the loan/application register needs deep knowledge, but most of the data on the register is captured by people who think of HMDA as someone else's job.

This post is about who to train and on what. For what the register contains and how filing works, see our guides to HMDA reporting requirements and HMDA reporting thresholds. For the pre-submission review, see HMDA data scrubbing.

The Deadlines Training Has to Beat

Two dates in Regulation C set the pace, and both arrive sooner than most staff expect.

Quarterly recording. Under 12 CFR 1003.4(f), a reporting institution must record data on its loan/application register within 30 calendar days after the end of the calendar quarter in which final action is taken. HMDA is not a year-end exercise; the register is meant to be maintained throughout the year.

Annual submission. Under 12 CFR 1003.5(a), the annual LAR is due by March 1 of the following year, and an authorized representative with knowledge of the data must certify its accuracy and completeness. Institutions that reported at least 60,000 covered loans and applications in the prior year, excluding purchased loans, also submit quarterly within 60 calendar days after each of the first three quarters.

The practical point for training: if staff learn HMDA in January, the year's data has already been captured. Training belongs before and during the collection year, with a refresher before the scrub.

Who Needs HMDA Training, and How Much

HMDA data passes through many hands. Each role needs a different slice of the rule.

Role	What they touch	Depth of HMDA training
Loan officers and MLOs	Application date, demographic collection, loan purpose, applicant information	Focused: collection rules and the fields they capture
Processors	Property data, income relied on, loan terms, updates during the file	Focused: field definitions and keeping data current
Underwriters	Action taken, denial reasons, debt-to-income and loan-to-value relied on	Focused: action taken and decision-related fields
Closers and post-closing	Final terms, rate, fees and points, closing date	Focused: final values and dates
HMDA coordinator / LAR staff	The whole register, edits, geocoding, submission	Deep: full Regulation C and the filing process
Compliance and fair lending staff	Coverage, data integrity, fair lending analysis	Deep: coverage, exemptions and analysis
Senior management	Certification, oversight	Overview: what is being certified and why it matters

Most banks over-train the coordinator and under-train the front end. The register can only be as good as what loan officers and processors put into it.

Loan Officers: The Collection Rules

Loan officers create the most consequential HMDA data, because they are the ones in front of the applicant.

Demographic information. HMDA requires the institution to collect ethnicity, race and sex, and to record whether that information was collected on the basis of visual observation or surname. The collection rules depend on how the application is taken. When an applicant in a face-to-face application declines to provide the information, the institution must note it on the basis of visual observation or surname; applications taken by mail, internet or phone follow different rules. Loan officers need to know which rule applies to each channel, how to ask without steering, and how to record a refusal correctly.

Application date and channel. The application date is a defined field, and the channel affects demographic collection. A loan officer who treats a phone call as a pre-qualification when it was in fact an application creates a timing and coverage problem.

Loan purpose and property. Purpose, occupancy and property type drive both coverage and reporting. Loan officers need to know the HMDA definitions, which do not always match how the bank's loan system labels the same thing.

Fair lending context. Loan officers should understand why the data exists. HMDA data feeds fair lending analysis by examiners and the public. Our post on fair lending laws covers the ECOA and Fair Housing Act framework that HMDA supports.

Processors and Underwriters: Field Integrity

Processors and underwriters change data during the life of the file, and HMDA reports the data the institution relied on at final action, not what was on the initial application.

Income relied on. HMDA asks for the gross annual income relied on in making the credit decision. If the underwriter recalculates income, the register needs the recalculated figure.

Ratios relied on. Debt-to-income and combined loan-to-value are reported as relied on, where the institution's partial exemption status does not remove them.

Action taken and denial reasons. The action taken code is the field most closely tied to fair lending risk. The difference between a denial, a withdrawal and a file closed for incompleteness is defined in Regulation C, and the underwriter's decision has to map to it accurately. Denial reasons need to match the file and the adverse action notice.

Property address and geocoding. A processor who corrects the property address in the loan system but not in the HMDA data, or vice versa, creates a geocoding error that cascades into census tract, county and state fields.

The training goal for this group is simple to state: when a fact in the file changes, the HMDA field changes with it.

Closers and Post-Closing

Final loan terms, rate spread inputs, fees, points, lender credits and closing dates all come late in the file. Post-closing staff need to know which closing figures feed HMDA fields and that they must be captured as final values. Many banks' rate spread and pricing errors trace back to a closing figure that was never updated in the HMDA record.

The HMDA Coordinator and LAR Staff

The person who owns the register needs the full rule, and more.

Whether the institution is a reporter, which transactions are covered, and whether partial exemptions apply. Several of these tests are reapplied every year; the asset-size threshold is adjusted annually, for example. Coverage is covered in depth in our thresholds post.
Partial exemptions. Smaller insured depository institutions that meet loan-volume tests may be partially exempt from reporting certain data points. Knowing exactly which fields drop out, and how to report them as exempt, is coordinator-level knowledge.
The filing process. Submitting through the HMDA Platform, resolving syntactical, validity and quality edits, and the certification.
Quarterly recording. Keeping the register current within 30 calendar days after each quarter, as the rule requires.
When to resubmit after errors are found, and how to document the decision.

The coordinator also needs to be the teacher. In most community banks, the coordinator is the only person who knows HMDA well enough to explain it, which makes their training the source of everyone else's.

Compliance and Fair Lending Staff

Compliance staff need to understand HMDA from two directions: as a reporting obligation that can be violated, and as a data set that will be analyzed for fair lending risk. That means knowing how examiners use the data, how pricing and underwriting disparities appear in it, and how to run the bank's own analysis before submission. Pre-submission fair lending review is one of the most useful things a compliance team can add to the HMDA cycle, and it requires a working knowledge of both HMDA and the fair lending laws.

Senior Management

The officer who certifies the register should understand what they are certifying. Regulation C requires certification by an authorized representative with knowledge of the data. A short session on what the register contains, the controls behind it, and the error rate from the scrub gives the certifying officer something real to stand behind.

When to Train

A calendar that matches the HMDA cycle:

Before the collection year, or at hire. Loan officers, processors and underwriters learn the collection rules and field definitions before they handle applications. New hires should not take applications before they are trained.
After each quarter. A short review of the quarter's edit results with the people who created the errors. This is the highest-return training of the year, because it uses the bank's own mistakes.
Before the scrub. The coordinator and compliance staff refresh on edits, partial exemptions and anything that changed in the rule or the filing instructions.
When the rule changes. Regulation C changes periodically, and the CFPB adjusts thresholds annually. Someone must own monitoring for changes and re-training the affected roles.
After a finding. An exam or audit finding on HMDA data should trigger targeted training for the roles that touch the affected fields, with the training recorded.

What to Look for in a HMDA Course

When choosing training, a few criteria separate useful courses from compliance theater.

Coverage of the current rule. HMDA has changed several times. Training should reflect current Regulation C and current thresholds, and the provider should be able to tell you when it was last updated.
Role relevance. A loan officer does not need the geocoding chapter. A coordinator does. Look for training you can assign by role.
Online access. HMDA collection staff are spread across branches and remote offices. Online delivery makes it practical to train everyone before they take applications.
Examiners ask for evidence of training. The course should produce a completion record you can file.
Connection to fair lending. HMDA training that never mentions why the data exists produces staff who treat demographic collection as a box to tick.

Matching Courses to Roles

The HMDA (Home Mortgage Disclosure Act) online course is the core course for anyone who touches HMDA data, from loan officers to LAR staff. Assign it to collection staff before they handle applications, and to coordinators and compliance staff as the foundation for their deeper work. The HMDA compliance training page lists the related options.

For the fair lending side, pair it with courses on the laws HMDA data is used to test:

For compliance staff who own HMDA alongside other mortgage rules, the Certificate in Mortgage Lending Compliance provides a broader program, and the Certificate in Lending Compliance Core Concepts is an option for staff building a lending compliance foundation.

Next Step

Do not wait for the scrub to discover who needs training. Assign the HMDA (Home Mortgage Disclosure Act) course to everyone who captures HMDA data this year, and plan a deeper session for your coordinator before filing season.

Frequently Asked Questions

Who needs HMDA training at a bank?

Anyone who captures or changes data that ends up on the loan/application register needs HMDA training, not just the person who files it. That includes loan officers and MLOs who take applications and collect demographic information, processors who handle property and income data, underwriters who set the action taken and denial reasons, closers who capture final terms, and the HMDA coordinator who assembles and submits the register. Compliance and fair lending staff need it to analyze the data, and the certifying officer needs an overview of what they are certifying.

Is HMDA training required by regulation?

Regulation C does not set a specific HMDA training requirement or frequency. It does require reporting institutions to collect accurate data, record it quarterly and certify the annual register as accurate and complete. In practice, examiners expect staff who collect and report HMDA data to be trained, and the absence of training is hard to defend when data errors are found. Training also forms part of a compliance management system, which examiners assess. Keep completion records for every role you train.

When should HMDA training happen?

Train collection staff before they take applications, either at hire or before the collection year begins, because errors are made at the point of capture. Review each quarter's edit results with the staff who created the errors, since data must be recorded within 30 calendar days after each quarter. Refresh the coordinator and compliance staff before the annual scrub, ahead of the March 1 submission deadline. Add targeted training whenever Regulation C changes or an exam or audit finds data errors.

What should loan officers learn about HMDA?

Loan officers need the demographic collection rules, including how to ask for ethnicity, race and sex without steering, how collection differs between face-to-face and remote applications, and when the institution must record information on the basis of visual observation or surname. They also need the HMDA definitions of application, loan purpose, occupancy and property type, which may differ from how the bank's loan system labels them. Above all, they need to understand that HMDA data is used for fair lending analysis.

What is the most important thing for HMDA LAR staff to know?

LAR staff need to know that the register reports the data the institution relied on at final action, which means their job is keeping HMDA fields aligned with the loan file as it changes. Beyond that, they need coverage and partial exemption rules, the edit categories, geocoding, quarterly recording within 30 days of quarter end, and the submission and certification process. They are usually the in-house teacher for everyone else, so their own training should be deep and kept current.

Does online HMDA training work for loan officers?

Yes, and for most banks it is the only practical way to train everyone who takes applications before they start. Loan officers and processors are spread across branches and remote locations, and online courses let them complete training on their own schedule while producing a completion record for the file. Online training works best when it is paired with short, bank-specific reviews of quarterly edit results, so staff see how the rules apply to their own files and their own errors.