Data methodology
What is HMDA data?
The Home Mortgage Disclosure Act (HMDA), enacted in 1975, requires most mortgage lenders to publicly report data about every loan application they receive. The Modified Loan Application Register (Modified LAR) is published annually by the Consumer Financial Protection Bureau (CFPB) and contains tens of millions of rows — one per loan application. It is the most comprehensive public record of U.S. mortgage lending activity.
Records included
Our rankings include only loans that meet all of the following criteria:
- Originated (action taken = 1) — the loan was actually made, not just applied for or denied
- First lien — primary mortgage, not a second mortgage or HELOC
- Principal residence — owner-occupied primary home, not investment property or vacation home
- Purchase (loan purpose = 1) — all medians and lender rankings are computed on home purchase loans only; refinance counts are shown separately for context
- Not business or commercial purpose
- Reported interest rate, total loan costs, and origination charges — rows where any of these fields are marked "Exempt" or "NA" are excluded
Why medians, not averages?
Medians are more robust than averages for fee data. A small number of very high-cost loans (jumbo mortgages, complex transactions) can pull the average far above the typical borrower's experience. The median represents the midpoint — half of borrowers paid more, half paid less — and is less influenced by outliers.
Volume thresholds
To prevent small-sample noise, lenders must meet minimum origination thresholds to appear in each ranking tier:
| Level | Min. volume |
|---|---|
| National lender rankings | 500 originations |
| State lender rankings | 50 originations |
| County lender rankings | 10 originations |
| County included in output | 100 originations (total) |
| Lender profile published | 100 originations (total) |
What “total loan costs” includes
The total_loan_costsfield in HMDA includes all lender-side origination charges, discount points, and third-party service fees (appraisal, title, settlement) as reported on the Loan Estimate. It does not include prepaid items (homeowner's insurance, property tax escrow) or transfer taxes. This is the closest HMDA field to “Section A + B” on your Closing Disclosure.
How lender names are resolved
HMDA records identify lenders by a Legal Entity Identifier (LEI) — a standardized 20-character code. We resolve LEIs to human-readable names in order:
- HMDA Public Panel— the CFPB publishes a companion file mapping each LEI to the institution's reported name
- GLEIF API — for LEIs not in the panel, we fall back to the Global LEI Foundation's public API
Corporate suffixes (LLC, Inc., N.A., FSB, etc.) are stripped when generating URL slugs. The full legal name is retained in the data.
Limitations
- Prior year data. HMDA is published roughly 12–18 months after the reference year. Our 2024 data reflects loans originated in 2024, not current market conditions.
- Individual variation.A lender's median costs reflect their mix of loan sizes, geographies, and borrower profiles — not a quote for your specific loan.
- Not all fees.Some fees (e.g., buyer's title insurance, transfer taxes) are reported separately or not at all in HMDA.
- Exempt disclosures.Lenders may report certain fee fields as “Exempt.” These rows are excluded from medians, which means some lenders' median costs may be understated if they systematically exempt reporting.