October 2026

To benchmark CRA and HMDA lending against peers, pick a group of lenders that compete in the same markets with a similar size and product mix, pull their public HMDA and CRA data for the same year and the same geography, and compare market share, lending by tract income level, denial rates and pricing. The comparison only holds up if the peer group does. Your own numbers mean little on their own. Say you hold a 6% share of home purchase originations in moderate-income tracts. That could be strong or weak, and nobody can tell which until it sits next to what lenders like you did in the same tracts in the same year. Examiners make that comparison as a matter of course, so it makes sense to make it first. This guide covers where the data comes from, how to build a peer group that will…

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HMDA, CRA and Section 1071 are three separate federal reporting regimes. HMDA (Regulation C) covers applications for dwelling-secured loans. CRA data reporting covers small business, small farm and community development loans at banks above the small bank size. Section 1071 (Regulation B, subpart B) will cover small business credit applications at lenders that originate at least 1,000 a year for two years running. They overlap more than their names suggest. All three hang on a census tract, two of them ask about demographics, and one loan can look like it belongs on two registers when the rules put it on only one. Below, the three sit side by side. Every threshold and date below comes from the current regulation text or the agency notice that set it, and the sources are listed at the…

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A fair lending regression tests whether a gap in a lending outcome, such as denial or the rate paid, between a prohibited basis group and a control group survives once the credit factors your policy actually uses are held constant. What survives is the part you will be asked to explain, and the model shows which applications drive it. This article covers the working side of that: what goes into the model, how to read what comes out, and how examiners use the result. It is the companion to what regression can and cannot prove in fair lending, which deals with the method's limits in detail, quoting the OCC's handbook. If you have not read that one, the short version is that a model can only account for the factors you give it. What is a fair lending regression actually testing? Two…

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A census tract is a small statistical subdivision of a county, drawn by the U.S. Census Bureau to hold between 1,200 and 8,000 people, ideally about 4,000. Lenders care because HMDA and CRA both record each loan's location by tract, and the tract's income level decides whether a loan counts as lending in a low- or moderate-income area. First published December 15, 2021, when lenders were switching to the 2020 census tracts. Rewritten October 13, 2026 as a current explainer for HMDA and CRA reporting. The 2021 transition notes are kept at the end. What counts as a census tract The Census Bureau's geography glossary defines census tracts as "small, relatively permanent statistical subdivisions of a county or statistically equivalent entity." They generally hold 1,200 to 8,000 people,…

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