HMDA data as a shopping tool for doctor loans: finding who actually writes 95%+ LTV jumbos

Physician loans from banks above HMDA’s reporting threshold appear in the public Loan/Application Register with loan amount, combined LTV, rate spread and whether the loan was sold. That data lets you test a lender’s marketing against what it closed last year.

Which physician-loan lenders report

A depository institution must report under Regulation C if it originated at least 25 closed-end mortgages in each of the two preceding years and has a branch in a metropolitan area, among other tests. That captures essentially every regional and national bank offering a doctor program; a small credit union program may fall under the threshold. Each covered application, not only closed loans, generates a record with about fifty fields, including the action taken and, on denials, up to four reasons.

The fields that describe a doctor loan

Several data points make physician loans visible in the public file. Combined loan-to-value above 95% on a purchase of a principal residence is rare outside FHA, VA, USDA and doctor programs, and the loan type field separates government loans out. Loan amount above the conforming limit combined with high CLTV narrows it further. Purchaser type shows whether the loan was sold within the year or held, confirming the “portfolio” claim. Rate spread records the difference between APR and the average prime offer rate, which is the cleanest public measure of how a lender prices its doctor loans against the market. The introductory rate period field shows 60, 84 or 120 months for 5/6, 7/6 and 10/6 ARMs, and the interest-only and balloon flags reveal non-QM features. Debt-to-income and credit score are collected but not released publicly.

How to use it before choosing a bank

The CFPB publishes the modified LAR for each institution and a filtering tool by county. Select purchases of principal residences, conventional loan type, CLTV above 90%, and your target county. Lenders that claim a physician program but show no high-CLTV conventional originations in your metro last year may be writing the product only in their home markets. Compare rate spreads between two banks for the same profile. Look at denial reasons: a high share of “credit history” or “debt-to-income” denials at high CLTV tells you how the program actually underwrites residents. None of this predicts your outcome, but it is the only independent check on a product that is never listed on rate comparison sites.

What the lender will ask you for the report

The application form asks for ethnicity, race and sex, with disaggregated categories, and the lender must request the information even when you apply by phone. You may decline; if you apply in person and decline, the loan officer records the data from observation. Age is reported from the application. The data is reported in a way that a physician relocating from another state cannot be individually identified, since the public file rounds loan amounts, suppresses age ranges at the extremes and omits the exact address.

Because doctor loans are underwritten outside GSE guidelines, fair-lending examiners rely on these same fields to test whether the flexible terms are offered evenly across race and sex within a bank’s physician portfolio.

What to check

• Pull the lender’s HMDA record for your county: principal-residence purchases, conventional type, CLTV above 90% — that is the doctor-loan footprint.
• Compare the rate spread of two banks’ high-CLTV jumbo loans; a consistent gap is the cost of the “relationship.”
• Check purchaser type to confirm loans stay on the balance sheet; a bank that sells them may change terms at the next sale.
• Read denial reasons at high CLTV to see whether the program in practice declines thin credit files.

Frequently asked questions

Are physician loans identifiable in HMDA data?

Not by name, but by profile. A conventional, principal-residence purchase with a combined loan-to-value above 95%, often above the conforming limit and held by the reporting bank, matches almost nothing except a doctor program. Filtering the public Loan/Application Register on those fields in your county shows which banks actually close such loans and at what rate spread.

Do I have to disclose my race and sex on a doctor loan application?

The lender must ask; you may decline. For a face-to-face application the loan officer will then record ethnicity, race and sex based on visual observation or surname, as Reg C requires. The data is used for fair-lending monitoring and appears only in aggregated or modified public files; it cannot be used to decide your application.

The rule in full: Home Mortgage Disclosure Act (HMDA) and Regulation C. The borrower profile: Physicians and licensed professionals. Related guides: Jumbo loans: requirements, rates and how they differ from conforming · PMI for first-time buyers: what it costs and how to get rid of 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 physicians and licensed professionals

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 · Conventional borrowers · Veterans · Self-employed · Investors · Retirees · Bad credit · Foreign nationals · Heroes · Rural buyers · Condo & second home · Refinancing