2025 HMDA Filing: Your Complete Preparation Checklist for March 2

The March 2, 2026 deadline for submitting your 2025 HMDA data is approaching. (Note: The deadline is March 2nd this year because March 1st falls on a Sunday.) Whether this is your first filing or your thirtieth, a structured preparation process helps ensure accurate, timely submission and avoids last-minute scrambling.

This checklist covers the essential steps compliance officers should complete before submitting to the FFIEC's HMDA Platform.

Key Dates to Remember

Before diving into the checklist, mark these critical dates:

• January 1, 2026: Begin final data review and validation
• February 15, 2026: Recommended internal submission deadline (allows buffer for corrections)
• March 2, 2026: CFPB filing deadline (no extensions granted) — moved from March 1 because it falls on a Sunday
• March 31, 2026: Modified LAR available for public disclosure review

Your Pre-Filing Checklist

1. Verify Data Completeness

Review your Loan Application Register (LAR) for completeness:

• Confirm all reportable applications and loans are included
• Check for missing records from Q4 2025 closings
• Verify purchased loan data is properly captured
• Ensure withdrawn and denied applications are included

Pro tip: Run a loan count reconciliation against your core system to catch any missing transactions.

2. Validate Geocoding Accuracy

Geocoding errors are among the most common causes of edit check failures. Your geocoding should achieve 95%+ accuracy to minimize resubmission risk.

Key geocoding checks:

• Verify all property addresses have valid census tract assignments
• Confirm state/county/tract combinations are valid for 2020 Census boundaries
• Check for addresses that failed geocoding and require manual review
• Validate that geocoded results align with your institution's lending footprint

Related:Learn about compliance-grade geocoding services

3. Run Edit Check Validation

The FFIEC HMDA Platform performs syntactical, validity, and quality edits. Run these checks internally before submission:

Syntactical Edits: Data format and structure requirements

• Field lengths and formats match specifications
• Required fields are populated
• Numeric fields contain valid numbers

Validity Edits: Logical consistency checks

• Action taken dates fall within reporting year
• Loan amounts are within reasonable ranges
• Rate spreads are calculated correctly for applicable loans

Quality Edits: Reasonableness checks

• Unusual patterns flagged for review
• Outlier values identified
• Geographic distribution makes sense for your institution

4. Review Rate Spread Calculations

Rate spread reporting requires accurate calculations based on the applicable APOR (Average Prime Offer Rate):

• Verify rate spread methodology matches CFPB requirements
• Confirm calculations use the correct APOR tables for lock dates
• Check that exempt transactions are properly identified
• Review any rate spreads that seem unusually high or low

5. Confirm Reportable Transaction Scope

Not all transactions are HMDA-reportable. Verify your data includes only reportable transactions:

Include:

• Applications received (approved, denied, withdrawn, incomplete)
• Loans originated
• Loans purchased from other institutions
• Preapproval requests (if applicable)

Exclude:

• Commercial purpose loans
• Loans secured by properties outside your assessment areas (in certain cases)
• Transactions below reporting thresholds

6. Validate LAR Formatting

Your LAR file must meet FFIEC specifications:

• Pipe-delimited format with correct field order
• UTF-8 encoding without BOM
• No header row in submission file
• LEI (Legal Entity Identifier) is current and valid
• Calendar year field matches reporting period

7. Test Submission Platform Access

Before the deadline crunch, verify your technical access:

• Confirm user credentials for HMDA Platform are active
• Test login to https://ffiec.cfpb.gov/filing/
• Verify your institution's LEI is recognized
• Review submission history from prior years

8. Complete Internal Sign-Off Process

Most institutions require management approval before submission:

• Prepare summary statistics for management review
• Document any data anomalies and explanations
• Obtain sign-off from compliance officer and/or executive
• Maintain documentation of review process for examiners

Common Last-Minute Issues to Avoid

Geocoding failures: Address standardization issues cause many edit failures. Validate addresses early, not the week before filing.

Missing Q4 transactions: Late-year closings often get missed. Run a final reconciliation in January.

Incorrect rate spreads: APOR table lookups must use the correct date. Double-check your methodology.

Platform access problems: Password expirations and credential issues cause unnecessary delays. Test access in January.

Underestimating correction time: Quality edits require explanations. Budget time for researching and documenting unusual patterns.

How Comply HMDA/CRA Streamlines Filing

Comply HMDA/CRA automates many of these checklist items:

• Integrated geocoding with 95%+ accuracy eliminates manual address lookups
• Built-in edit checks match FFIEC logic, catching errors before submission
• Rate spread calculator uses current APOR tables automatically
• LAR export generates properly formatted submission files
• Audit trail documents your review process for examiners

Ready to Simplify Your HMDA Filing?

Don't wait until February to discover data issues. Schedule a demo to see how Comply HMDA/CRA can streamline your 2025 filing process.

For institutions already using Comply, our support team is available to assist with any filing questions. Contact us for immediate assistance.

RATA Associates has helped financial institutions meet HMDA compliance requirements since 1987. Our Comply software suite is trusted by banks and credit unions nationwide for accurate, efficient regulatory reporting.