Got a rejected HMDA file from the CFPB portal? First thing to check: make sure your Universal Loan Identifier (ULI) starts with your Legal Entity Identifier (LEI) and runs 23–45 characters long. Eight out of ten rejections trace back to ULI format mistakes.
What is HMDA and why does the data matter?
HMDA stands for the Home Mortgage Disclosure Act. It forces most U.S. lenders to collect and report 26 data points for every mortgage application or loan they originate by 2026. The whole point? Spot discriminatory lending patterns and keep credit access fair for everyone.
Step-by-Step: Submit clean HMDA data
Before you start: You’ll need a Legal Entity Identifier (LEI) from the Global LEI Foundation and a CFPB institution ID.
- Collect the raw data
- Ethnicity, race, sex, gross annual income, and age (if the applicant provides it)
- Loan purpose—is it a home purchase, refinance, or home improvement?
- Action taken—did you originate the loan, approve but the borrower didn’t accept, deny it, or did the applicant withdraw?
- APR, DTI, loan term, property type (1–4 family), and occupancy (owner-occupied or not)
- ULI—23 to 45 characters that must begin with your LEI
- Match your raw fields to HMDA’s 2026 Regulation C codes
Raw field HMDA field Format / code Ethnicity Ethnicity1 1=Hispanic or Latino, 2=Not Hispanic or Latino, 3=Information not provided Race Race1–Race5 Codes 1–99 from Appendix A Sex Sex 1=Male, 2=Female, 3=Joint, 4=Sex not provided Income Income Whole dollars only—no commas or decimals Loan purpose Loan Purpose 1=Home purchase, 2=Home improvement, 3=Refinancing Action taken Action Taken 1=Originated, 2=Approved not accepted, 3=Denied, 4=Withdrawn ULI ULI 23–45 characters, must start with LEI - Run the CFPB’s validation checks in your LOS or HMDA tool
- Test every file against the 2026 edit checks before you export anything.
- Fix every “Hard Edit” error—missing income on an originated loan is a classic example.
- Clean up “Quality Edit” warnings too, like an APR that’s way outside the benchmark range.
- Export and send the file
- Format has to be pipe-delimited text (.txt) or pipe-separated values (.psv).
- Name it InstitutionID_YYYY.txt—so 1234567890_2026.txt, for instance.
- Upload through the CFPB’s filing platform before March 1, 2027.
If it still doesn’t go through
- ULI still wrong? Grab a fresh LEI (about $250) and re-issue every loan’s ULI.
- Wrong action code?
- Double-check the 2026 HMDA guide. Code 2 (approved but not accepted) is commonly mis-coded as 3 (denied).
- Missing ethnicity or race? Reach out to the applicant within 30 days—Regulation B lets you collect it verbally.
Keep rejection headaches away
- Automate ULI creation inside your LOS so every new loan gets a valid ULI on day one.
- Run quarterly mock submissions with the CFPB’s 2026 mock filing tool to catch problems early.
- Drill staff on Reg B scripts: “Federal law requires us to ask: Are you Hispanic or Latino? (Yes/No/Don’t know).”
- Keep HMDA archives for at least three years after you file; examiners may ask for samples.
