HMDA Reportability Checker

How the checker decides

It asks four questions in the order Regulation C asks them, and it stops at the first one that settles the answer. That order follows the CFPB's own compliance aids for institutional coverage and transactional coverage.

1. Is the institution a financial institution under 1003.2(g)? If not, nothing it does is reportable.
2. Is the transaction a covered loan? It has to be an application, origination or purchase of a closed-end mortgage loan or open-end line of credit secured by a dwelling, it has to be new credit, and no exclusion in 1003.3(c)(1) through (10) or (13) can apply.
3. Does your origination volume reach the product's threshold? Under 1003.3(c)(11) and (c)(12), an institution covered for one product can still be outside the rule for the other.
4. Is the transaction partially exempt under 1003.3(d)? If it is, it still goes on the LAR, just without the optional data fields.

Every result shows each step it ran, whether that step passed, and the section that decided it, so you can check the reasoning against the rule rather than taking the verdict on trust.

Institutional coverage

A bank, savings association or credit union is a depository financial institution under 1003.2(g)(1) when it meets all five of these tests:

• Assets. Above the asset threshold on the preceding December 31. For 2026 data collection the threshold is $59 million, measured on December 31, 2025 (comment 2(g)-2; Federal Register document 2026-00087). The CFPB adjusts it every year by the change in the CPI-W.
• Location. A home or branch office in an MSA on the preceding December 31.
• Lending activity. At least one home purchase loan, or refinancing of one, secured by a first lien on a one- to four-unit dwelling, originated in the preceding calendar year.
• Federal connection. Federally insured or regulated, or that loan was federally insured, guaranteed or supplemented, or intended for sale to Fannie Mae or Freddie Mac.
• Loan volume. At least 25 closed-end mortgage loans in each of the two preceding calendar years, or at least 200 open-end lines of credit in each of them.

A for-profit mortgage lender that is not a depository is a nondepository financial institution under 1003.2(g)(2) when it has a home or branch office in an MSA and meets the same loan-volume test. There is no asset test for nondepositories. A nondepository also counts as having a branch office in an MSA if, in the preceding year, it took applications for, originated or purchased five or more covered loans on property in that MSA or metropolitan division (1003.2(c)(2)).

"Each of the two preceding calendar years" means both years have to clear the count. For 2026 those are 2024 and 2025. One strong year does not make up for a weak one (comment 2(g)-1). Mergers have their own rules, set out in comments 2(g)-3 and 2(g)-4, and this checker does not model them.

Transactional coverage and exclusions

Regulation C reports applications received, loans originated and loans purchased (1003.4(a)). Each has to involve a covered loan, which 1003.2(e) defines as a closed-end mortgage loan or an open-end line of credit that is not excluded under 1003.3(c). Both of those terms require a lien on a dwelling (1003.2(d) and (o)). A few consequences catch people out:

• Purpose does not limit coverage for consumer loans. A dwelling-secured home equity loan for tuition is a covered loan. Purpose only narrows coverage when the credit is primarily for a business or commercial purpose: then it is covered only if it is a home purchase loan, a home improvement loan or a refinancing (1003.3(c)(10)). A loan to buy or improve a rental property, or to refinance one, is therefore still reportable (comment 3(c)(10)-3).
• Collateral decides, not the loan's use. A loan to buy a home that is secured only by a personal guarantee is not a closed-end mortgage loan (comment 2(d)-1). A home equity loan on house A used to buy house B is a home purchase loan (comment 2(j)-1).
• Modifications are not new credit. A transaction that modifies, renews, extends or amends a debt without satisfying and replacing it is not an extension of credit. Assumptions are the exception, and so are New York CEMAs (comment 2(d)-2). Draws on an existing line are not extensions of credit either (comment 2(o)-2).
• Prequalifications are not applications under Regulation C (comment 2(b)-2). Preapproval requests are reported only if denied, approved but not accepted, or turned into a home purchase loan (1003.4(a)).

The exclusions in 1003.3(c) then remove specific transactions:

• (c)(1) loans originated or purchased in a fiduciary capacity, such as trustee;
• (c)(2) loans secured by unimproved land, unless the proceeds will build or place a dwelling on it within two years (comment 3(c)(2)-1);
• (c)(3) temporary financing: bridge loans and construction-only loans designed to be replaced by separate permanent financing to the same borrower, and construction-only credit to build a dwelling for sale. A construction loan that converts to permanent financing with the same lender is not temporary financing, and neither is a short fix-and-flip loan just because its term is short (comment 3(c)(3)-1);
• (c)(4) purchases of an interest in a pool of loans;
• (c)(5) purchases of servicing rights only;
• (c)(6) loans acquired in a merger or acquisition, or with all the assets and liabilities of a branch office;
• (c)(7) loans and applications for a total of less than $500;
• (c)(8) purchases of a partial interest. Buying 100 percent of a loan is not excluded (comment 3(c)(8)-1);
• (c)(9) loans used primarily for agricultural purposes, including loans secured by a dwelling on land used primarily for agriculture (comment 3(c)(9)-1);
• (c)(10) business- or commercial-purpose credit that is not a home purchase, home improvement or refinancing;
• (c)(11) closed-end loans, if you originated fewer than 25 closed-end mortgage loans in either of the two preceding years;
• (c)(12) open-end lines, if you originated fewer than 200 open-end lines of credit in either of the two preceding years;
• (c)(13) new funds advanced before a New York CEMA, when both get final action in the same calendar year.

The two volume exclusions are optional. An institution below a threshold may still report that product, but then it has to report all of that product for the year (comments 3(c)(11)-2 and 3(c)(12)-2).

Partial exemptions

The partial exemptions come from the Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018 (CFPB summary of the 2019 rule), and they let smaller insured lenders report a covered loan with fewer fields. Under 1003.3(d)(2) and (3), an insured depository institution or insured credit union that originated fewer than 500 closed-end mortgage loans in each of the two preceding calendar years does not have to collect or report the optional data for its closed-end loans. The same applies separately to open-end lines of credit at fewer than 500.

The partial exemption is unavailable in three cases:

• Nondepository lenders are not insured depository institutions or insured credit unions. A subsidiary of an insured institution does not inherit its parent's eligibility either (comment 3(d)-5).
• Insured depository institutions with a weak CRA record lose it: a "needs to improve" rating on each of the two most recent CRA exams, or "substantial noncompliance" on the most recent one, as of the preceding December 31 (1003.3(d)(6)). Credit unions are not examined under the CRA, so this carve-out does not reach them.
• Volume of 500 or more in either year for that product.

The optional data are listed in 1003.3(d)(1)(iii) by paragraph of 1003.4(a). In plain terms: the universal loan identifier (a non-universal loan identifier is reported instead), the property address, rate spread, credit score, reasons for denial, total loan costs or total points and fees, origination charges, discount points, lender credits, interest rate, prepayment penalty term, debt-to-income ratio, combined loan-to-value ratio, loan term, introductory rate period, non-amortizing features, property value, the two manufactured home fields, multifamily affordable units, application channel, the loan originator's NMLSR ID, automated underwriting system, and the reverse mortgage, open-end and business-purpose flags. Everything else, including action taken, census tract, and applicant ethnicity, race and sex, is still reported.

Limits of this tool

This is a screening aid, not legal advice. It reads the rule as of the date above and answers for one transaction at a time. It does not model:

• mergers and acquisitions during the year, which change both coverage and partial-exemption eligibility (comments 2(g)-3, 2(g)-4 and 3(d)-1 through 3(d)-3);
• institutions exempt under a state disclosure law (1003.3(a));
• how to code the transaction once it is reportable. Loan purpose, action taken and the other fields follow the 2026 Filing Instructions Guide;
• quarterly reporting, which applies to institutions that reported at least 60,000 covered loans and applications, combined and excluding purchases, for the preceding year (1003.5(a)(1)(ii)).

Close calls on dwelling status, primary use, business purpose or temporary financing turn on facts this form cannot see. Read the commentary cited in each result, and ask your counsel or your regulator when the facts are unusual. Once you know a loan is reportable, the rate spread calculator works out its rate spread and the edit-check validator tests a LAR row against the FFIEC edits. Comply HMDA/CRA/SBL applies these rules across your whole register before you file.

Sources

Methodology: every threshold, exclusion and section number on this page was read from the eCFR text of 12 CFR part 1003 and its official interpretations (Supplement I), with title 12 up to date as of October 8, 2026, and from the CFPB's 2026 asset-threshold notice. The step order follows the CFPB's coverage compliance aids. Last reviewed October 13, 2026.

• 12 CFR part 1003 (Regulation C), sections 1003.2 to 1003.5, eCFR, up to date as of October 8, 2026.
• Supplement I to Part 1003, Official Interpretations, eCFR, up to date as of October 8, 2026.
• Home Mortgage Disclosure (Regulation C) Adjustment to Asset-Size Exemption Threshold, CFPB, Federal Register document 2026-00087, January 7, 2026.
• HMDA institutional coverage and HMDA transactional coverage, CFPB compliance aids, February 22, 2023.