HMDA on a conforming loan: the demographic questions, rate spread and what goes public
Your lender reports your conforming application to HMDA with its outcome, rate spread, LTV, DTI and demographic data you may decline to provide; the published records let you see how that lender treats borrowers like you.
The section of the application you can leave blank
The “Demographic Information” section of the Uniform Residential Loan Application exists because Regulation C requires covered lenders to collect ethnicity, race and sex, and to report age and income, for every application. You may decline; in a face-to-face application the loan officer must then record the information by visual observation or surname. Declining has no effect on DU or LPA and cannot be used in underwriting. A loan officer who pressures you to fill it in, or who says the AUS needs it, is wrong on both counts.
What is reported about a conforming purchase
For a loan delivered to Fannie Mae or Freddie Mac the lender reports loan type “conventional,” purpose (purchase, refinance or cash-out), occupancy, the loan amount, combined LTV, DTI, credit score and scoring model, the rate spread between your APR and the average prime offer rate, discount points and lender credits, total loan costs, the interest rate, and whether the loan is a high-priced or high-cost mortgage. Reporting thresholds exempt very small lenders, but essentially every bank, credit union and non-bank mortgage lender a move-up buyer would use is covered. Denials are reported with reasons, which is why lenders document “debt-to-income” or “collateral” carefully.
Reading the public file before you pick a lender
The CFPB publishes a modified loan-level file each year with certain fields removed or bucketed to protect privacy; your name and exact address are not in it, though census tract, loan amount range and demographics are. Repeat buyers can use the public data to see a lender’s conventional denial rates, median rate spread and share of high-priced loans in a county. A lender whose conforming purchase loans show a rate spread consistently above peers is pricing aggressively or adding overlays; that is worth asking about before you apply.
Privacy and the quirks worth knowing
Rate spread is reported for every originated loan, so a low-score borrower with heavy LLPAs will appear in the data as a wider spread; that does not by itself signal a problem with the lender. Withdrawn applications and files closed for incompleteness are reported too. If you start applications with three lenders to compare Loan Estimates, each one becomes a HMDA record, which is harmless but explains why a lender may keep asking for documents after you have moved on.
What to check
- You may decline the demographic questions; underwriting does not use them and the AUS does not require them.
- Before choosing a lender, compare its conventional denial rate and median rate spread for your county in the public HMDA data.
- A denial must be reported with a reason — ask for the same reasons in writing under ECOA to understand what to fix.
- Your personal identity is not published, but loan amount range, census tract and demographic data are.
Frequently asked questions
Will refusing to state my race or ethnicity affect my conforming loan approval?
No. Regulation C allows applicants to decline, and the lender must note that choice. Desktop Underwriter and Loan Product Advisor do not read those fields. If you apply in person, the loan officer records observed ethnicity, race and sex, which is a reporting requirement rather than an underwriting input.
Can I see what my lender reported about my loan?
Not your individual record by name, but the CFPB publishes modified loan-level data that includes the lender, the year, the census tract, the loan amount range, purpose, rate spread and outcome. You can locate records matching your loan closely enough to confirm the reported rate spread and loan type, and compare the lender’s overall pattern with others.
The rule in full: Home Mortgage Disclosure Act (HMDA) and Regulation C. The borrower profile: Conventional loan borrowers. Related guides: Conventional loan requirements: credit, down payment, DTI, reserves, property · Conforming loan limits: how the FHFA number works and what happens above it · Credit score needed to buy a house: minimums by loan type, and what it costs to be average · FHA vs conventional for a first-time buyer: which loan wins, and when.
Other federal rules for conventional loan borrowers
TILA / Reg Z · RESPA · TRID disclosures · ECOA · Fair Housing Act · SAFE Act / NMLS · ATR / QM · HOEPA · HPA / PMI · Servicing rules · FCRA · Flood insurance · MARS rule · SCRA · LO compensation
HMDA for other borrowers
First-time buyers · Veterans · Self-employed · Investors · Retirees · Bad credit · Foreign nationals · Physicians · Heroes · Rural buyers · Condo & second home · Refinancing