As of January 1, 2026, mortgage lenders and financial institutions face significant updates to Home Mortgage Disclosure Act (HMDA) reporting requirements. These changes, stemming from the CFPB's October 2023 final rule, expand data collection while attempting to balance regulatory burden reduction with improved data utility. Whether you're a community bank, credit union, or non-depository lender, understanding these updates is critical to maintaining compliance and avoiding penalties.
The most substantial change involves reporting for closed-end mortgage loans. Instead of the previous home purchase and home improvement loan categories, lenders must now collect and report approximately 50 additional data points for closed-end mortgages. Key new fields include:
These enhanced data points allow regulators and researchers to better understand lending patterns, risk characteristics, and fair lending compliance across the mortgage industry.
HMDA reporting for open-end lines of credit, including home equity lines of credit (HELOCs), has also expanded. Lenders above the exemption thresholds must now report:
The good news for smaller lenders: partial exemptions apply to institutions with fewer than 500 open-end lines annually, reducing reporting obligations by an estimated 20% according to CFPB analysis.
Understanding whether your institution must report under HMDA is the first compliance step. The permanent thresholds from the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) of 2018 remain in effect:
These thresholds have reduced the number of affected institutions by approximately 400 annually, providing meaningful relief to smaller community lenders while preserving data coverage for the vast majority of mortgage activity.
Lenders should be aware of these critical dates:
The HMDA Platform will enforce the new XML schema and edit validations, making pre-submission testing mandatory. Lenders using loan origination systems like Encompass or Calyx should work with their vendors to ensure system updates are complete well before data collection begins.
On March 13, 2026, President Trump signed an executive order directing the CFPB to consider further mortgage regulatory reforms, including raising the asset threshold for HMDA exemption and excluding mortgage inquiries from reporting scope. While these potential changes would not affect 2026 reporting requirements, they signal a regulatory environment increasingly focused on burden reduction for community lenders.
To prepare for the 2026 HMDA reporting cycle:
Non-compliance penalties can reach up to $44,539 per violation in 2026 based on CPI adjustments, making proactive preparation essential.
The 2026 HMDA reporting changes represent the most significant expansion of mortgage data collection since the 2018 amendments. While the new requirements add complexity, they also provide regulators and industry stakeholders with richer data to evaluate fair lending practices, market trends, and credit access. Lenders who begin preparation now—updating systems, training staff, and testing submissions—will be well-positioned for a smooth transition into the new reporting regime.
For detailed guidance on specific data points and institutional applicability, consult the CFPB's 2023 HMDA Small Entity Compliance Guide and the FFIEC HMDA Resources at ffiec.cfpb.gov.