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.
Here's a critical insight many professionals overlook: HMDA data is not a static snapshot. It's a living, evolving dataset that undergoes continuous refinement long after its initial publication.
Lenders have the ability to submit corrections and late filings throughout the year. Mortgage applications data for recent years is subject to ongoing updates and revisions. The CFPB eventually "closes the books" on older datasets, but this process extends for several years - the overtime periods we call out above. Based on Polygon Research's extensive experience analyzing HMDA data, we've consistently observed:
Leveraging the most current and accurately interpreted HMDA data is a strategic imperative that provides distinct competitive advantages across various industry functions.
Staying abreast of HMDA data releases empowers lenders to achieve true market positioning, allowing you to precisely understand your standing and performance against competitors in a dynamic market. This precision also enables proactive compliance monitoring, ensuring your fair lending analysis is built on the most accurate foundation and effectively mitigating risk. Ultimately, up-to-date HMDA insights facilitate sharpened strategic planning, helping you identify genuine market opportunities and inform your expansion strategies with reliable, actionable competitive intelligence.
For those shaping policy and uncovering market truths, HMDA data is indispensable. It enables robust policy analysis, allowing for the accurate identification of emerging trends and a precise assessment of policy impact through a deep understanding of data timing and revisions. Regulators benefit from targeted examination planning, utilizing the most current data for precise risk assessments and efficient examination focus. How many times have we seen academic research 'just' published but on data that is 3-5 years old? The market and regulations have moved on, and those conclusions are misleading at best. Researchers can ensure valid academic research, safeguarding the integrity and validity of their studies by working with the appropriate "vintage" of HMDA data.
In the world of investment and financial analysis, timely and accurate data is king. We've already seen the pace of consolidation and M&A increase in 2025. HMDA provides the foundation for informed Due Diligence, crucial for conducting thorough M&A analysis and portfolio assessments with a clear understanding of data limitations and recency. It fuels dynamic and comprehensive market research, driving sound investment decisions with access to the most recent market insights available. Finally, it supports accurate risk assessment, allowing for the refinement of portfolio risk models and stress tests using the most current loan performance indicators.
To truly harness the power of HMDA data, adopt these best practices.
This means you have to allocate resources for analysis updates immediately following the Spring Modified LAR release. Come summer, refresh your analysis to see how late or updated filings may have changed your analysis with the National Loan Level Dataset release. From there, periodically refresh your strategy updates and business planning cycles. Finally, build agility into your compliance monitoring programs to account for ongoing data refinements.
We cannot stress enough how important it is to maintain data provenance. Always document the specific data version and release date used for any analysis or report. You will still have to actively monitor for significant updates that could materially alter your conclusions, but you will know when and how you formed your initial findings.
Compare the full, current HMDA data with other open data and with your own internal year-to-date transactions. HMDA has data points that are not available anywhere else, and has them at the loan level - use this to decipher your competitors' strategy and to drive your own.
Today's mortgage landscape is characterized by a powerful convergence of technological innovation, changing regulatory focus, and fluctuating market dynamics. The accelerated adoption of AI in mortgage technology is transforming operations, with lenders increasingly embracing AI to enhance efficiency. Yet rapid technological advancement always puts a strain on existing frameworks and policies, including those around transparency and fairness, which in turn leads to heightened regulatory scrutiny. This is nowhere seen more clearly than with the AI sea change we're living through, and this has not escaped the CFPB's notice: "creditors must be able to specifically explain their reasons for denial. There is no special exemption for artificial intelligence." This firm stance mandates a comprehensive and diligent approach to HMDA analysis, not just for the HMDA use cases we've been discussing, but also to put yourself in a position both to reason with and to fact check your AI. Own your story, through mastery of the most definitive, detailed mortgage data source available - HMDA.
Ready to transform your market intelligence with professional-grade HMDA analysis? Contact us today to discover how Polygon Vision provides real-time access to the most current HMDA data, coupled with powerful analytical tools designed specifically for mortgage industry leaders. Or if you are ready to jump in, get a free trial of Polygon Vision.