2025 HMDA Filing: Your Complete Preparation Checklist for March 2

Status note, updated 18 August 2026. This checklist was written for the 2025 data / March 2026 filing cycle, and that cycle has closed — the dates below are kept as a worked example rather than as upcoming deadlines. The eight preparation steps themselves do not change from year to year, so the checklist is still the one to work through. For the 2026 data year, the filing deadline is 1 March 2027, which falls on a Monday and so needs no adjustment.

The March 2, 2026 deadline for submitting your 2025 HMDA data is a Monday, and that is the only reason it is not March 1: the usual date falls on a Sunday this year. Whether this is your first filing or your thirtieth, working through a structured preparation process is what keeps the last week of February from turning into a scramble. This checklist covers the steps compliance officers should complete before submitting to the FFIEC's HMDA Platform.

Key Dates to Remember

The shape of the calendar is the same every year, so it is worth learning the rule rather than the dates. Regulation C sets the filing deadline at 1 March following the calendar year being reported; where 1 March falls on a weekend the deadline moves to the next business day. No extensions are granted either way. Work backwards from there: begin final data review and validation at the start of January, and set an internal submission deadline around the middle of February so you keep roughly two weeks of buffer for corrections without touching the real deadline. Your modified LAR becomes available for public disclosure review at the end of March.

For the 2025 data year that meant 1 January 2026 to start review, 15 February 2026 as an internal deadline, 2 March 2026 to file (1 March was a Sunday) and 31 March 2026 for disclosure. For the 2026 data year the deadline is 1 March 2027, a Monday, so there is no weekend shift to account for.

Your Pre-Filing Checklist

1. Verify Data Completeness

Start by reconciling your Loan Application Register against your core system, because a loan count that does not match is the fastest way to find records that never made it in. The gaps tend to cluster in predictable places: Q4 2025 closings booked late in the year, loans purchased from other institutions, and applications that were withdrawn or denied rather than originated. All of those are reportable, and all of them are easy to lose when the LAR is assembled from an export that was scoped to closed loans. Comply HMDA/CRA can automate the LAR preparation steps in this checklist, from completeness checks through submission.

2. Validate Geocoding Accuracy

Geocoding errors cause more edit check failures than any other single data problem, and you should be targeting 95%+ accuracy to keep resubmission risk down. Every property address needs a valid census tract assignment, and each state, county and tract combination has to be valid for 2020 Census boundaries rather than an earlier vintage. Pull the addresses that failed geocoding entirely into a manual review queue, because they will not fix themselves and they will fail at the Platform. It is also worth sanity-checking the geocoded results against your institution's actual lending footprint: a cluster of records in a market you do not lend in usually means an address parsing problem rather than a new branch. You can geocode the LAR before you file instead of checking these after the fact, and RATA offers compliance-grade geocoding services for institutions that would rather outsource the step entirely.

3. Run Edit Check Validation

The FFIEC HMDA Platform runs three categories of edit against your file, and all three can be run internally first. Syntactical edits check format and structure: field lengths and formats matching the specification, required fields populated, numeric fields containing numbers. Validity edits check logical consistency, so action taken dates have to fall within the reporting year, loan amounts have to sit in a reasonable range, and rate spreads have to be calculated for the loans that require them. Quality edits are reasonableness checks that flag unusual patterns, outlier values, and geographic distributions that do not look right for an institution of your size and footprint. Quality edits do not block submission, but each one you leave unexplained is a question an examiner can ask later.

4. Review Rate Spread Calculations

Rate spread reporting depends on the applicable Average Prime Offer Rate, and the errors here are almost always about which APOR table was used rather than the arithmetic. Confirm your methodology matches CFPB requirements, then confirm the calculation pulled the correct table for each loan's lock date rather than the current one. Exempt transactions need to be identified as exempt rather than left blank or calculated anyway. Finally, look at the tails: any rate spread that seems unusually high or low is worth checking by hand before it becomes a quality edit you have to explain. You can calculate the rate spread for every reportable loan against the current APOR tables with our free calculator when you need to verify a figure outside your software.

5. Confirm Reportable Transaction Scope

Not every transaction belongs in the file. Include applications you received in any disposition, whether approved, denied, withdrawn or closed for incompleteness, along with loans you originated, loans you purchased from other institutions, and preapproval requests where applicable. Exclude commercial purpose loans, transactions below reporting thresholds, and in certain cases loans secured by properties outside your assessment areas. Over-reporting is a real risk, not only under-reporting: a record that should not be in the file still gets edit-checked, still gets published in your modified LAR, and still has to be defended.

6. Validate LAR Formatting

The submission file itself has to meet FFIEC specifications before the Platform will accept it. That means a pipe-delimited file in the correct field order, UTF-8 encoding without a byte order mark, and no header row. Two fields cause most of the format-level rejections at this stage: your Legal Entity Identifier, which must be current and valid rather than expired, and the calendar year field, which must match the reporting period rather than the year you are filing in.

7. Test Submission Platform Access

Technical access is the cheapest item on this list to verify and the most annoying one to discover on deadline day. Log in to the HMDA Platform at https://ffiec.cfpb.gov/filing/ in January and confirm your credentials are still active, since passwords expire and staff turnover leaves accounts behind. While you are in there, check that the Platform recognizes your institution's LEI and pull up your submission history from prior years, which is useful context for the sign-off package below.

8. Complete Internal Sign-Off Process

Most institutions require management approval before anything is submitted, and that approval is easier to get when the package is already assembled. Prepare summary statistics for management review, document any data anomalies alongside the explanation for each, and obtain sign-off from your compliance officer or an executive. Then keep the documentation. The record of who reviewed what, and why an unusual pattern was left as it was, is exactly what examiners ask for later, and reconstructing it from memory in year three is not realistic.

Common Last-Minute Issues to Avoid

The problems that derail filings in late February are almost always problems that were visible in January. Address standardization issues cause geocoding failures, which cause edit failures, so validate addresses early rather than the week before filing. Late-year closings get missed, which is why the January reconciliation in step one matters. Rate spreads calculated against the wrong APOR date look correct until they do not. Password expirations and credential problems stop a submission dead for reasons that have nothing to do with your data.

The one that catches people out most often is underestimating correction time. Quality edits require explanations, and researching an unusual pattern well enough to document it properly takes considerably longer than fixing a syntactical error. Budget for it.

How Comply HMDA/CRA Streamlines Filing

Comply HMDA/CRA automates most of this checklist. Integrated geocoding with 95%+ accuracy removes manual address lookups. Built-in edit checks match FFIEC logic and catch errors before submission rather than after. The rate spread calculator uses current APOR tables automatically, so the wrong-table problem in step four does not arise. LAR export generates properly formatted submission files, and the audit trail documents your review process for examiners without anyone assembling it by hand.

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, so 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.