HMDA
How to Benchmark Your CRA and HMDA Lending Against Peer Data
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…
HMDA vs CRA vs Section 1071: What Each Rule Collects and Who Has to File
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…
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…
How to Evaluate Fair Lending and CRA Software: What to Test Before You Sign
Every fair lending and CRA software evaluation starts the same way: a shortlist of vendors, a run of demos that all look competent, and a decision that has to be defended internally on something firmer than which interface felt nicer. The difficulty is that the differences between these products are mostly invisible in a demo. They show up eighteen months later, in an examination, when someone asks how a number was produced and the honest answer turns out to be that nobody knows. This is a guide to testing for that in advance. It is written from our side of the table — we sell one of these products — so treat the last section as the interested party it is. The first six are the questions we would ask any vendor in this category, including ourselves. What does fair lending…
HMDA Plus: What It Actually Changed in the LAR Workflow
The short version. If you have been told HMDA Plus is coming, the date is wrong by about a decade. It is the industry nickname for the expansion the CFPB proposed in 2014 and finalised on 15 October 2015, and most of it took effect on 1 January 2018. It is not a proposal you need to prepare for. It is the reason your LAR looks the way it does now. That matters more than a correction, because a good deal of the material still circulating about it is written in the future tense. If your process was built after 2018 you inherited the outcome without seeing the transition; if it was built before, some of the workarounds from that first filing season are probably still in it. Either way the useful question is not what HMDA Plus proposed. It is what it did to the workflow, and which of those…
- California's New Fair Lending Exam Law: What State-Chartered Banks, Credit Unions and Mortgage Licensees Should Have Ready
- Fair Lending Regression Analysis: What It Controls For and How to Explain a Pricing Disparity
- What a Fair Lending Exam Actually Asks For
- Fair Servicing: What Examiners Test in Servicing Data, and How to Test It First
- What Actually Counts as a Small Business Loan Under Section 1071
- How to Fix the 10 Most Common HMDA Edit Check Errors
- CFPB and DOJ Settle Redlining Claims Against Non-Depository Mortgage Companies Before Change in Administration
- CFPB, DOJ Order Trident Mortgage Company to Pay More Than $22 Million for Deliberate Discrimination Against Minority Families
- Fair Lending Self-Assessment: A Step-by-Step Guide for 2026
- CFPB takes action against Nationstar Mortgage for flawed mortgage loan reporting
- CFPB Takes Action Against Fifth Third Bank for Auto-Lending Discrimination and Illegal Credit Card Practices
