Determine whether a loan application, origination, or other action is reportable under the Home Mortgage Disclosure Act (HMDA, Regulation C, 12 CFR Part 1003). Checks institutional coverage, transaction coverage, LAR action codes, and required data collection fields.
Regulation C12 CFR 1003Zero PIIClient-Side
Scope & reliance — All inputs are processed locally in your browser. No data is transmitted. Do not enter real personal data. Asset thresholds reflect the 2024 HMDA reporting year ($56M depository threshold). CFPB adjusts the threshold annually via Federal Register. Verify against current CFPB guidance before relying on this output for compliance decisions. Deterministic logic · no inference · zero PII · CC BY 4.0.
Step 1 · Institution Coverage Test
Depository institutions (bank, credit union, savings assoc.) use asset-size threshold. Nondepository mortgage companies use loan volume threshold.
For depository institutions: must exceed $56M (2024 threshold, 12 CFR 1003.2(e)). Nondepository: enter total assets; loan volume thresholds apply instead.
Institutions operating exclusively outside Metropolitan Statistical Areas (MSAs) are not required to report HMDA data (12 CFR 1003.2(e)).
Required condition for institutional coverage (12 CFR 1003.2(e)). A single qualifying first-lien origination in the prior year satisfies this test.
Step 2 · Transaction Coverage Test
Only loans secured by a dwelling are covered. Commercial non-dwelling and unimproved land are not covered transactions.
Demographic data collection (race/ethnicity/sex) is required for applications secured by 1–4 unit owner-occupied dwellings.
Used for LAR reporting; does not affect reportability determination for most transactions.
Manufactured homes are covered dwellings under Regulation C whether titled as real or personal property (1003.2(f)).
Step 3 · Action Taken & Product Type
Maps directly to HMDA LAR Action Taken field (12 CFR 1003.4(a)(8)). All covered actions must be reported.
HELOCs are covered open-end lines of credit secured by a dwelling. Nondepository institutions must originate ≥100 open-end lines in either of prior 2 calendar years to be covered for this product type.
Institutional Coverage · 12 CFR 1003.2(e)
Transaction Coverage · 12 CFR 1003.2(e), 1003.3
LAR Action Taken Code · 12 CFR 1003.4(a)(8)
Required LAR Data Fields · 12 CFR 1003.4
Compliance Flags & Exemption Notes
Regulatory Citations
1. Home Mortgage Disclosure Act (HMDA), 12 U.S.C. § 2801 et seq. — Foundational statutory authority. Requires covered financial institutions to collect and report data on mortgage loan applications and originations.
2. Regulation C, 12 CFR Part 1003 — CFPB implementing regulation (2018 HMDA Rule, effective Jan 1, 2018 for most provisions). Defines covered institutions, covered transactions, and required data fields.
3. CFPB HMDA Small Entity Compliance Guide (2018) — Plain-language institutional and transaction coverage tests; exemption criteria for depository and nondepository institutions.
4. CFPB HMDA Reportable Transactions FAQs — Guidance on coverage edge cases including manufactured housing, HELOCs, purchased loans, and commercial-purpose transactions.
5. Annual HMDA Asset-Size Exemption Threshold, Federal Register — $56M threshold for 2024 reporting year (depository institutions). Adjusted annually; CFPB publishes in Federal Register each December.