2026 HMDA Data: Your Filing Checklist for the March 1, 2027 Deadline

HMDA data collected during 2026 is due on the HMDA Platform by March 1, 2027. That date is a Monday, so this cycle has no weekend shift to plan around. 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, and every requirement in it is linked to the FFIEC or CFPB document it comes from. The governing document for this cycle is the 2026 Filing Instructions Guide (FIG), which the FFIEC describes as the guide for "HMDA data collected in 2026" filed with the CFPB in 2027.

Key Dates for the 2027 Filing

Regulation C sets the annual deadline at March 1 following the calendar year the data covers, and when that day falls on a Saturday or Sunday, a submission made the following Monday counts as timely (12 CFR 1003.5(a)(1)). The FFIEC filing FAQ says the Platform opens for each annual filing period on January 1. For 2026 data that gives you:

• January 1, 2027: the HMDA Platform opens for 2026 submissions.
• Mid-February 2027: a sensible internal deadline. It leaves roughly two weeks to research quality edits without touching the real one.
• March 1, 2027 (Monday): the filing deadline.

The Platform stays open after March 1 for late filings and resubmissions. If you file late, the FAQ tells you to contact your federal HMDA supervisory agency if you want to explain why. Institutions that reported at least 60,000 covered loans and applications (excluding purchased loans) in the preceding year also file quarterly, within 60 calendar days after each of the first three quarters end. After the year closes, Regulation C also requires a written notice at your home office, and at each branch in an MSA or MD, telling the public that your modified LAR is available on the CFPB's website (12 CFR 1003.5(c)).

What Changed Since Last Year's Filing

Not much, and the FIG says so directly: "There are no significant changes to the submission process for data collected in 2026 and reported in 2027," and "the required data fields for the 2026 data have not changed from the 2025 data collection." The 2026 FIG version log does list a handful of smaller changes, and one threshold moved:

• The file format section now says outright not to use scientific notation in any field (their example is "102.03E4"). This one tends to bite institutions that build the LAR in a spreadsheet, since Excel will turn a long number into scientific notation without asking.
• Edit V695 is stricter. The Mortgage Loan Originator NMLSR Identifier must be four to seven digits and cannot exceed 3000000. The 2025 version allowed four to twelve digits.
• Quality edit Q621, which also checked the NMLSR ID, was removed because it duplicated V695.
• The Property Value examples now show that decimal values are acceptable.
• The asset-size exemption rose to $59 million. Banks, savings associations and credit unions with assets of $59 million or less as of December 31, 2025, are exempt from collecting data in 2026. For 2025 data the figure was $58 million (Federal Register, January 7, 2026).

The loan-volume thresholds did not change. Closed-end mortgage reporting still applies at 25 originations in each of the two preceding calendar years, and open-end line reporting at 200 (12 CFR 1003.2(g)). For 2026 data, the two years that count are 2024 and 2025.

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 2026 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. The transmittal sheet's Total Number of Entries also has to match the number of LAR rows you upload, or the file fails edit S304. Comply HMDA/CRA can automate the LAR preparation steps in this checklist, from completeness checks through submission.

2. Validate Geocoding Accuracy

Every property address needs a census tract, and the tract has to be right for the year you are reporting. The FIG tells filers to enter the 11-digit tract number and to "use the boundaries and codes effective January 1st, of the calendar year covered by the loan/application register," so 2026 records get the codes in effect on January 1, 2026. Our note on the 2020 Census explains which census tract boundaries apply to your HMDA geocoding and when the 2020 geography took over. Three edits check this. V625 requires a valid 11-digit tract or NA. V627 requires the first five digits of the tract to match the reported county FIPS code. Q603 flags a record reported NA for tract when its county has more than 30,000 people. 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 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 Platform runs four types of edit, all listed in section 5 of the 2026 FIG, and you can run every one of them internally first. Syntactical edits check the file structure and filing year. Validity edits check for valid values in each field: V619, for example, requires the action taken date to fall in the reporting year. You cannot submit until every syntactical and validity error is corrected and the file is re-uploaded. Quality edits check whether values look reasonable (Q606 flags income of $10 million or more), and macro quality edits test the file as a whole, such as multifamily loans making up more than 10% of entries. An earlier version of this article said quality edits do not block submission, and that was wrong. Under the FIG, you cannot submit until you either confirm each flagged value on the Platform or correct it and upload again. Before you get there, you can validate the file against the edit checks before you submit one row at a time, and our guide to fixing the 10 most common HMDA edit check errors maps each frequent failure to its 2026 edit number.

4. Review Rate Spread Calculations

Regulation C defines rate spread as the difference between the loan's APR and the Average Prime Offer Rate for a comparable transaction "as of the date the interest rate is set" (12 CFR 1003.4(a)(12)). It applies to covered loans and approved-but-not-accepted applications subject to Regulation Z, other than assumptions, purchased loans and reverse mortgages. Most errors here come from the lookup, not the arithmetic: the calculation pulled the APOR for the closing date or the current week instead of the rate-set date. Check a sample against the historical APOR tables, and recalculate the rate spread for individual loans with our free calculator when a figure looks off. V657 requires Rate Spread to be NA or Exempt when action taken is 3, 4, 5, 6 or 7, or when the loan is a reverse mortgage. Exempt applies only to partially exempt transactions, since rate spread is one of the optional data points under 12 CFR 1003.3(d). Finally, look at the high end: Q610 flags a first-lien origination with a rate spread above 6.5% that is not reported as a high-cost (HOEPA) loan, and Q611 does the same for subordinate liens above 8.5%.

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. 12 CFR 1003.3(c) sets out what to leave out. The exclusions that come up most often are loans made primarily for a business or commercial purpose (unless they are a home purchase, home improvement or refinancing), agricultural-purpose loans, loans secured by unimproved land, temporary financing, and transactions under $500. Closed-end loans are also excluded if you originated fewer than 25 of them in either 2024 or 2025, and open-end lines if you originated fewer than 200. 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. To test one transaction against these rules, our free HMDA reportability checker walks it through coverage, the exclusions and the partial exemptions, citing the section that decides each step.

6. Validate LAR Formatting

The submission file has to meet section 3.3 of the FIG before the Platform will accept it, and none of these rules changed this year apart from the scientific notation line. It is a pipe-delimited .txt file. The first row is the transmittal sheet and starts with 1, and every row after it is a loan or application and starts with 2 (edit S300). Do not pad fields with leading zeros, do not wrap text in quotes, and do not use scientific notation. Three fields cause most of the format-level rejections: the LEI, which must be 20 characters (V600) and must match the transmittal sheet on every row (S301); the calendar year, which must match the filing year you picked at the start of the filing (S302); and the entry count covered in step one. The FFIEC's File Format Verification Tool checks the delimiter, field count and integer formatting before you get anywhere near an upload.

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. The filing FAQ explains that the Platform authenticates users by your institution's registered email domain, so personal addresses are not allowed, and staff turnover can leave nobody with a working account. Confirm in December who will file and that they can log in to the HMDA Platform. The HMDA Beta Filing Platform is open all year as a sandbox, and the CFPB does not keep what you upload there, so you can run a test file of your 2026 data through the real edits in the fall. Leave time for the upload as well. The FAQ warns that very large files can take a day to finish.

8. Complete Internal Sign-Off Process

Certification happens inside the Platform, where an authorized representative with knowledge of the data certifies its accuracy and completeness. Most institutions also require management approval before that happens, and approval is easier to get when the package is already assembled. Prepare summary statistics for management review, document any data anomalies with the explanation for each, and record who confirmed each quality edit and why. Then keep the documentation. Regulation C requires you to retain a copy of the submitted LAR for at least three years (12 CFR 1003.5(a)(1)(i)), and the record of why an unusual pattern was left as it was is what examiners ask for later. Reconstructing that from memory two years on does not work.

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 98%+ 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 handles your 2026 data before the March 1, 2027 deadline. 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.