How we built this report
The Q1 2026 Closing Cost Index analyzes mortgage loans originated in 2025 by U.S. lenders, sourced from the Federal Financial Institutions Examination Council’s (FFIEC) Home Mortgage Disclosure Act (HMDA) Modified Loan/Application Register. The CFPB published the 2025 Modified LAR on March 31, 2026.
Data sources
Primary: HMDA 2025 Modified LAR, published by CFPB on March 31, 2026.
Supplementary: State-by-state benchmark data compiled by FairPriceCheck from authoritative state agency publications — Department of Insurance rate filings, county recorder fee schedules, and state statutes governing transfer taxes.
What HMDA includes
- Loan amount, interest rate, lender (LEI), borrower demographics, location
- Origination charges, discount points, lender credits
- Total loan costs (top-line)
- Loan purpose (purchase, refinance, cash-out)
What HMDA does not include
- Title insurance breakdown (lender’s vs. owner’s policy)
- Recording fees
- Transfer tax (state-specific, separate)
- Prepaid interest, escrow deposits
- Detailed fee-by-fee breakdown beyond the three itemized categories above
For these categories, our state pages reference benchmark data compiled separately and acknowledge the limitation explicitly.
Sample size and statistical thresholds
- A lender appears in state-level rankings only with at least 30 records in that state.
- A lender appears in national rankings only with at least 100 records nationally.
- Press-quotable findings require at least 100 records in the relevant cell.
- Percentile claims require at least 30 observations in the comparison group.
- State pages publish only when the state has at least 1,000 total records and at least 5 qualifying lenders.
Lender identification
Each loan is tied to a Legal Entity Identifier (LEI), the global standard for entity identification. Lender names are resolved via the GLEIF API. Some institutions appear under multiple LEIs (subsidiaries, mergers); we resolve these to a single canonical entity where possible.
Excluded records
- Foreign banks with minimal U.S. mortgage activity
- Specialty lenders with fewer than 10 records nationally
- Records with unresolvable lender LEI
- Records flagged as multi-family or commercial
How grades are assigned
A lender’s grade compares its median total loan costs to the peer average for similar loans (same state, same loan type). Grade thresholds:
- A: median ≤ 90% of peer average
- B: median 90–100% of peer average
- C: median 100–110% of peer average
- D: median 110–125% of peer average
- F: median > 125% of peer average
Grades are only assigned with sufficient sample size on both the lender and the peer group.
Limitations and disclosures
- HMDA reports lender-side data, not borrower-side. Some borrower-paid fees may not be captured.
- Discount points data is reported but may include lender-paid points in some cases — the dataset does not always distinguish.
- HMDA data is annual, not quarterly. Quarterly framing reflects our publication cadence, not the underlying data granularity.
- “Closing costs” in this report refers specifically to HMDA’s total_loan_costs field, which excludes prepaid items and escrow deposits.
- State and national medians shown in this report are computed as report-count-weighted aggregations of per-lender medians. This approximates the true cross-borrower median while remaining computable from pre-aggregated lender summaries.
Updates and future reports
This is the inaugural Q1 2026 Closing Cost Index. Future quarterly reports will incorporate updated HMDA data as released by CFPB, plus borrower-side data from completed audits via Fair Loan Check and Fair Closing Check.
Citation
If citing this report, please use:
FairPriceCheck. (2026). Q1 2026 Closing Cost Index. Available at https://www.fairpricecheck.com/closing-cost-index/