HMDA and borrowers over 62: what lenders report about your age and reverse mortgage

Since 2018 every HMDA record carries the applicant’s age and a reverse-mortgage indicator, which is how regulators test for age disparities and how a retiree can see which lenders actually close reverse or small loans in a county.

Data points that describe an older applicant

Regulation C requires covered lenders to report, for each application, the applicant’s age (from the date of birth on the application), whether the loan is a reverse mortgage, whether it is open-end, the income relied on, the debt-to-income ratio, the combined loan-to-value ratio, the credit score and scoring model, the automated underwriting result, the action taken and the reasons for denial. Ethnicity, race and sex are collected through the demographic questions you may decline to answer; age is not optional because it is drawn from the application itself. The public version of the data shows age in bands (55-64, 65-74, over 74) and carries a separate indicator for applicants 62 and older, while credit score and exact income are released only in ranges or withheld.

What the age field is used for

Examiners compare denial rates, pricing and product mix across age bands within one lender and against peers. A reverse-mortgage lender whose over-74 borrowers pay higher origination charges than its 62-to-64 borrowers, or a bank that denies applicants over 65 at twice the rate with similar ratios, will be asked to explain. HMDA does not itself prohibit anything; it is evidence for ECOA and Fair Housing enforcement. For you, the practical consequence is that reporting your age is not a reason for denial and that a lender may not refuse to take an application to keep a bad data point off its file.

Who does not report

A lender is covered only if it made at least 25 closed-end mortgages in each of the two preceding years (200 for open-end lines), has an office in a metropolitan area and meets asset thresholds. A small community bank, a credit union with light mortgage volume, or a private individual who seller-finances is absent from the data. Reverse mortgages, once exempt, have been reportable since 2018 when the lender meets the thresholds, so the data now reveals which institutions are active in HECM lending by county.

Using the public data before you apply

The FFIEC and CFPB publish the modified loan application register and a browsing tool. Filter by county, reverse-mortgage flag and year to see which lenders closed reverse loans, their median rate spread and denial rates; filter by small loan amounts to find who lends $60,000 against a paid-off house in a rural area. The data reports originations, not service quality or complaints, and it says nothing about how a servicer treats a surviving spouse. Pair it with the NMLS record described under the SAFE Act and with the CFPB complaint database before choosing.

What to check

• Answer the demographic questions or decline; your age is recorded either way and is not a denial reason.
• Use the HMDA browser filtered by county and reverse-mortgage flag to list active HECM lenders.
• Remember that small lenders and seller financers do not appear in the data at all.
• Check denial rates for your age band at a lender before paying an application fee.

Frequently asked questions

Does reporting my age under HMDA affect my approval?

No. The age field exists so that regulators can detect age-based disparities after the fact; it plays no role in the credit decision, and a lender that used it to decline you would be violating ECOA. What influences approval is the income, assets, credit and ratio data, which the lender reports alongside age but evaluates under its own guidelines.

Can I see how many reverse mortgages a lender made near me?

Yes. HMDA data since 2018 includes a reverse-mortgage indicator for lenders that meet the reporting thresholds. The public data browser lets you filter by county, lender and the reverse flag, and shows counts, denial rates and rate spreads. Lenders below the 25-loan threshold are missing, so an absent lender is not necessarily inactive.

The rule in full: Home Mortgage Disclosure Act (HMDA) and Regulation C. The borrower profile: Retirees and senior borrowers. Related guides: Conventional loan requirements: credit, down payment, DTI, reserves, property · Conventional vs FHA vs VA vs USDA: the four loan types compared · 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 retirees and senior 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 · Conventional borrowers · Veterans · Self-employed · Investors · Bad credit · Foreign nationals · Physicians · Heroes · Rural buyers · Condo & second home · Refinancing