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HMDA - Getting it Right in 2025

Have you been looking for the 2025 HMDA Getting It Right! Guide on the FFIEC website? We couldn't find it either. Here are some tips for working with your 2025 HMDA data from the resources that are still available.

By way of background, for many years the Federal Financial Institutions Examination Council (FFIEC) has annually issued A Guide to HMDA Reporting: Getting it Right! for the Home Mortgage Disclosure Act (HMDA). It summarizes key provisions of HMDA and its implementing regulation, Regulation C. The regulation requires financial institutions subject to HMDA reporting to collect and report on certain data fields about applications, originations and purchases of "covered loans." The last time the Guide was updated was in January 2024, for use with 2024 HMDA data.

By now, your 2024 HMDA data has been filed. In fact, on March 31, 2025, the 2024 Modified LAR was released by the FFIEC. A combined file containing all Loan/Application Register (LAR) records in a single file is also available on the FFIEC HMDA website.

You are likely starting to work on reviewing your 2025-Q1 HMDA data, and if you are required to do quarterly filings, you are getting ready for submission by May 30, 2025. Where do you go if there is no 2025 HMDA Getting it Right Guide?

The definitive instructions for HMDA are located in the annual Filing Instructions Guide (FIG), and fortunately, there is a FIG for 2025 data. The 2025 Online FIG is also located on the FFIEC HMDA website, and is available to help you file HMDA data collected in 2025.

The changes between HMDA 2024 and 2025 filings are listed in the FIG chapters 1 and 2 and include updated 2025 file and edit specifications, as well as updates to the submission process. Section 2.2 states that the data fields to be collected and reported have not changed:

The required data fields for the 2025 data have not changed from the 2024 data collection and reporting requirements. Please refer to Regulation C, the 2018 HMDA Rule, and the Data Specification section for the 2025 requirements.

Ultimately, the FIG and the HMDA regulation are the sources you should rely upon for filing. Use caution if you are referencing the 2024 Getting It Right! manual to navigate idiosyncrasies of the regulation as you conduct your review.

HMDA data collection and reporting can be challenging, as many data fields have nuanced requirements. Accuracy in reporting is critical, as the tolerance threshold for the percentage of errors requiring the reporter to resubmit its data is low, ranging from 2.5% to 10%, depending on the number of HMDA loans reported.

Without a 2025 Getting It Right publication, you will need to do a little extra work by pairing the 2025 FIG with the 2024 Guide. We also put the 2024 Getting It Right Guide here at BankersOnline Tools for your convenience, as it did disappear from the FFIEC website for a bit. Let's hope the FFIEC updates the Getting It Right Guide for 2025 soon!

First published on 04/01/2025

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