HMDA Reportable Transactions 2026: What Requires a LAR Entry

HMDA reporting requirements catch many MLOs off guard because the lines are not intuitive. Not all loans are reportable. Not all covered loans are reported the same way. And getting it wrong triggers regulatory scrutiny. This is a practical primer on what goes on the LAR and what does not.

Which Institutions Must Report

• ✦Banks, credit unions, and mortgage companies that originated at least 25 closed-end mortgage loans in each of the two preceding years must file a HMDA LAR.
• ✦Institutions with a smaller portfolio may be exempt from reporting. Confirm your institution's reporting threshold annually.
• ✦The institution files the LAR, not the individual MLO. But individual loan officers must understand reportability so files are flagged correctly.

What Transactions Are Reportable

• ✦Purchase money mortgages secured by a dwelling: reportable if originated by a covered institution.
• ✦Refinances and cash-out refinances secured by a dwelling: reportable.
• ✦Home improvement loans secured by the dwelling: reportable.
• ✦Home equity lines of credit: reportable if the institution has originated at least 500 open-end lines in each of the preceding two years.
• ✦Reverse mortgages: reportable.
• ✦Construction loans: reportable if they are construction-to-permanent. Stand-alone construction loans with no permanent phase are generally not reportable.

What Is Not Reportable

• ✦Loans on properties not in MSAs or MD areas and the institution has no branch in those areas: exemption may apply.
• ✦Loans to purchase or improve rental properties of five or more units are generally not covered by HMDA.
• ✦Business purpose loans: loans made primarily for business rather than personal purposes are excluded from HMDA.
• ✦Agricultural loans: excluded.
• ✦Temporary financing: bridge loans intended to be replaced by permanent financing are not reportable as separate transactions.

Application vs. Originated vs. Withdrawn

• ✦Every covered application must be reported, not just closed loans. Withdrawn applications, denials, and incomplete applications all appear on the LAR with the appropriate action taken code.
• ✦This is where many lenders create compliance gaps: pulling credit and then losing contact with the borrower without reporting an incomplete application status.