The Home Mortgage Disclosure Act (HMDA) requires certain institutions to collect and report mortgage loan data each year. One key factor is the loan volume threshold. Institutions that otherwise meet Regulation C’s institutional coverage criteria must report HMDA data on closed-end mortgage loans if they originated at least 25 closed-end mortgage loans in each of the two preceding calendar years. Data collected each year must be submitted by March 1 of the following year.

 

Example:

Suppose your bank originated the following HMDA reportable loans:

  • 2023: 30 loans
  • 2024: 28 loans
  • 2025: 24 loans
  • 2026: 22 loans
  • 2027: 27 loans
  • 2028: 29 loans
  • 2029: 31 loans

Backward Looking (Determining 2025 obligation):

Because you had more than 25 loans in both 2023 and 2024, you must report for 2025, even though you only had 24 loans in 2025.

Forward Looking (Determining 2026-2029 obligations):
Reporting Year Lookback Years HMDA LAR Collection & Filing Required
2025 2023 & 2024 Yes
2026 2024 & 2025 No
2027 2025 & 2026 No
2028 2026 & 2027 No
2029 2027 & 2028 Yes
For any given reporting year, you look back at the two prior calendar years:

 

  • If BOTH years ≥ 25 → You must report
  • If EITHER year < 25 → You do not report

This backward-looking test means institutions should track loan counts annually and anticipate when reporting will resume.

If you have any questions about your HMDA reporting obligations or need assistance interpreting these requirements, contact CCI today. Our compliance experts are ready to help you stay informed and compliant.

 

Sarah Smith, CRCM, CAFP