What Lenders Need to Know About the 2026 HMDA Reporting Changes

Last reviewed September 8, 2026. Claims are re-checked against their cited sources on review.

Corrections, September 8, 2026. An earlier version of this article carried four claims that do not hold. Each is listed with the correct fact beside it, so a reader who saw the earlier version can check it directly.

It attributed the 2026 requirements to a CFPB final rule of October 2023. No such rule exists. The data point expansion is the 2015 HMDA Final Rule, effective January 1, 2018.

It said roughly 50 data points were added for closed-end loans effective January 1, 2026. No data points were added in 2026. The 2026 change is the asset size exemption threshold, covered below.

It gave a 60 loan closed-end reporting threshold for depository institutions. The threshold is 25 loans, in each of the two preceding calendar years.

It gave non-depository lenders a combined 100 loan test. There is no combined test. The same 25 and 200 loan thresholds apply to them, independently, and the asset size test applies only to depositories.

Every claim below is cited to a primary source.

What actually changed for 2026

One thing changed in Regulation C for 2026, and it is a number. The asset size exemption threshold rose from $58 million to $59 million, effective January 7, 2026 (Federal Register 2026-00087, CFPB final rule).

A bank, savings association or credit union whose total assets were at or below $59 million on December 31, 2025 is exempt from collecting and reporting HMDA data for its 2026 activity. The adjustment follows a 2.5 percent increase in the Consumer Price Index for Urban Wage Earners and Clerical Workers for the twelve months ending November 2025, which is how this threshold moves every year.

That is the whole of the 2026 change. No data points were added, no reporting categories were expanded, and the submission mechanics are unchanged.

The data points did not change in 2026

The expanded HMDA data set is real, and it is eight years old. The 2015 HMDA Final Rule took the collection to roughly 48 data points, about 25 of them new, effective January 1, 2018 (CFPB Regulation C final rules, CFPB executive summary of the 2015 rule).

The fields most often presented as new arrivals sit in that 2018 set. Closed-end indicator, business or commercial purpose, reverse mortgage indicator, amortization type, interest only indicator, balloon indicator and loan term in months have all been reportable since 2018. The same is true of the open-end fields: maximum line amount, initial draw amount, introductory rate indicator and the purpose of the line.

The CFPB’s 2023 HMDA work is sometimes cited as the origin of a data point expansion. It was not. That year’s activity concerned the closed-end reporting threshold following the 2022 judicial vacatur, plus the routine December 2023 asset threshold adjustment for 2024. Neither added a field.

Who has to report

Institutional coverage turns on origination counts, and the two tests operate independently:

Closed-end mortgages: 25 or more originated in each of the two preceding calendar years.
Open-end lines of credit: 200 or more originated in each of the two preceding calendar years.

Meeting one test triggers reporting for that category alone. An institution over the closed-end threshold and under the open-end threshold reports its closed-end originations and nothing else.

The 25 loan closed-end threshold is the 2015 rule’s figure. A 2020 rule raised it to 100, and the U.S. District Court for the District of Columbia vacated that increase on September 23, 2022, which restored 25 (CFPB, Federal Register 2022-27204). There has never been a 60 loan threshold.

The asset size test is the piece that distinguishes institution types, and it works the opposite way round from how it is usually described. The $59 million threshold applies only to depository institutions. Non-depository lenders have no asset size test at all: they are subject to the same 25 and 200 origination thresholds, with no combined count and no dollar cutoff (CFPB HMDA reporting requirements and FAQs).

Submission timing

Data collected during calendar year 2026 is submitted to the HMDA Platform by March 1, 2027, the same annual deadline that has applied throughout (CFPB HMDA reporting requirements). There is no new schema, no new validation regime and no additional testing obligation for the 2026 cycle, because there are no new fields to validate.

Civil penalty amounts for HMDA violations are adjusted annually for inflation. Check the CFPB’s current adjustment directly rather than a figure quoted in an article, including this one.

Recent executive order may bring additional relief

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. The order’s full set of directives, and what each one would and would not change, is covered in what the 2026 executive order means for community banks.

What lenders should do now

The work for 2026 is confirmation, not implementation:

Check your asset size against the threshold. Depositories: total assets as of December 31, 2025 against $59 million. Non-depositories: this test does not apply to you.
Check your origination counts. Closed-end and open-end separately, for both 2024 and 2025, against 25 and 200.
Leave your data fields alone. If your system was collecting correctly in 2025, it is collecting correctly in 2026.
Diarise March 1, 2027 for the 2026 submission.
Treat undated compliance content with suspicion. The claims corrected at the top of this page circulate widely and are stated with confidence in several places.

The bottom line

2026 is a quiet year for HMDA. The threshold moved by a million dollars and nothing else in Regulation C changed. The genuinely significant expansion of mortgage data collection happened in 2018, and an institution reporting correctly last year has no new fields to build this year.

If the change you are preparing for is not in the list above, check its source before you spend on it.