The Home Mortgage Disclosure Act (HMDA) data stands as the bedrock of mortgage industry intelligence, offering unparalleled transparency to lenders, regulators, and market researchers. However, many industry professionals don't fully understand the careful choreography involved in collecting, releasing, and continuously updating this critical data throughout the year.
If your role touches mortgage lending, fair lending compliance, market analysis, or housing policy, a deep understanding of HMDA data releases isn't merely beneficial—it's essential to informed decision-making and strategic growth. At Polygon Research, we transform HMDA data into strategic intelligence, providing the clarity you need to navigate complex market dynamics.
Under Regulation C, covered lenders are mandated to submit their complete Loan Application Register (LAR) for the previous year by March 1st. For many, this submission is the final buzzer and they can head to the locker room. But the officials (the CFPB) keep the game going, and some lenders head back onto the court as well. The first important thing to understand is that the Consumer Financial Protection Bureau (CFPB) orchestrates HMDA data publication through two primary releases - Spring (Modified LAR) and Summer (National Loan Level Dataset).
The Spring Release consists of the public version of the lending data each covered lender submitted to the CFPB by March 1, combined into a single file and published by the end of March.
Key characteristics of this edition include:
The Summer HMDA dataset, the National Loan Level Dataset, incorporates the value-added fields mentioned above and comes in two flavors: Snapshot and Dynamic. The Snapshot version, while published in June or July, usually has a May publication date - this year it is May 19, 2025. As the name implies, this is a point-in-time against which the CFPB and other perform benchmark analysis. By contrast, the Dynamic version fulfills an important aspect of the Reg C and HMDA itself: ongoing, up-to-date transparency and clarity on the full story for the year. We spell this out below, but first, let's take a look at some of the value-added fields.
Users of our flagship HMDA analysis tool, HMDAVision, have access to these right away in the Spring, because the CFPB makes their algorithms public, and we put them to use right away with the Modified LAR data in the Spring. But if you're downloading the data yourself, starting with the National Loan-Level data in the Summer you'll find:
The derived Race and Ethnicity fields are used in applicant-based fair lending analysis. For place-based fair lending (like redlining analysis), you need Census tract data on minority status and income levels. The Summer releases provide this in the form of a handful of Census fields curated by the FFIEC. Once more, these are available already in the Spring from the FFIEC and the Census Bureau, and Polygon Research includes them from the outset.
One notable change this year is that the CFPB did not publish a Reporter Panel file like they normally do with the Snapshot publication of the National Loan Level Dataset. However, this information still available via API. Polygon Research is happy to field inquires about specific lenders.
This means that any analysis done on HMDA in the spring could be significantly different by summer.
Here's a real example: When we first reported the 2024 results on April 1st, 2025, we counted 6,149,171 total originations. By June, that number had grown to 6,176,068 - an increase of 26,897 loans that weren't captured in the spring release.
It is important to stay on top of these changes and be able to explain the nature of the data and the changes that follow HMDA releases.
Recent industry shifts underscore the critical importance of sophisticated HMDA data analysis driven by accelerated AI adoption, heightened regulatory scrutiny on AI, and dynamic market shifts.
According to recent industry reports, see our analysis of the GAO report, AI software adoption among lenders is rapidly increasing, primarily driven by the pursuit of operational efficiency. However, this growth also introduces new complexities. The CFPB has clearly articulated that "creditors must be able to specifically explain their reasons for denial. There is no special exemption for artificial intelligence." This mandates comprehensive HMDA analysis to proactively ensure and demonstrate fair lending compliance in the age of AI. Finally, the mortgage market continues to see significant fluctuations in application and origination volumes. These shifts directly impact how lenders assess market positioning, allocate resources, and manage compliance risk – making up-to-date HMDA insights more crucial than ever.
HMDA data is an extraordinary, foundational resource for understanding the intricate dynamics of the mortgage market. However, its true power is only unleashed when you're working with the most current, accurately processed, and expertly interpreted information. Deriving value from HMDA data begins with this deep understanding of timing of data releases. Knowing how complete your data source is, will give you explainability of your sources. Having a partner like Polygon Research with systems capable of rapidly incorporating new releases and distilling meaning, provides an undeniable competitive advantage.
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