Reading the public data

How to read HMDA data for multifamily and investor loans

HMDA is the one public file that lists individual apartment and rental-house loans by lender, amount, county and year. It covers loans on dwellings only, and not every lender reports.

By Research desk, The Lender Report ·Sources reviewed · 7 minute read · For Brokers, Borrowers, Bankers

The short answer

HMDA data is a yearly public file of mortgage loans reported under Regulation C. For commercial work it is useful for two things: loans on multifamily buildings of five or more units, and business-purpose loans on 1-4 unit rentals that are purchases, improvements or refinancings. It shows lender, amount, county and often rate and loan to value. It leaves out offices, stores, warehouses and construction-only loans.

What HMDA is

The Home Mortgage Disclosure Act requires many lenders to collect and report data on mortgage loans and to disclose it to the public. The rule that carries it out is Regulation C, 12 CFR part 1003, written by the Consumer Financial Protection Bureau. Each covered lender files a loan register by March 1 for the calendar year before, and the Bureau publishes the registers after modifying them “to protect applicant and borrower privacy.”

Most of the file is home loans to people who live in the home. A slice of it is commercial: apartment buildings and rental houses. That slice is why a broker or an investor should know how to read it.

Who reports

A lender is a “financial institution” under the rule, and must report, if it meets a set of tests in 12 CFR 1003.2(g). Two of them matter here.

  • Size, for banks and credit unions. A bank, savings association or credit union must have had assets on the preceding December 31 above a threshold the Bureau publishes each year. The threshold moves with inflation, so check the current notice and do not rely on a remembered figure.
  • Volume, for every lender. In each of the two preceding calendar years the lender must have originated at least 25 covered closed-end mortgage loans, or at least 200 covered open-end lines of credit.

Lenders that are not banks or credit unions report too, if they are for-profit mortgage lenders that meet the volume test. That is why the file names debt funds, agency lenders and private lenders that file nothing else in public.

A lender below the tests does not appear at all. A small bank with a handful of apartment loans each year can be an active local lender and have no HMDA record.

Which commercial loans are in, and which are out

The rule covers closed-end mortgage loans and open-end lines secured by a dwelling. A multifamily dwelling is one that “contains five or more individual dwelling units.” Section 1003.3(c) then takes loans back out. The exclusions that shape the commercial slice:

What Regulation C leaves out (12 CFR 1003.3(c), selected)

Exclusion Paragraph What it means for a searcher
Loans on unimproved land (c)(2) Land loans are not in the file
Temporary financing (c)(3) Construction-only and bridge loans meant to be replaced are generally not in the file
Loans used primarily for agricultural purposes (c)(9) Farm loans are not in the file
Business or commercial purpose loans, unless the loan is a home purchase loan, a home improvement loan or a refinancing (c)(10) An investor’s purchase or refinance of a rental is in. A business line secured by a rental, used for something else, is out
Purchases of a partial interest in a loan (c)(8) Participations bought are not reported by the buyer

Put together: a purchase or refinance of an apartment building is reported by a covered lender. So is a purchase or refinance of a rental house by an investor. A loan on an office, a store, a warehouse, a hotel or a self-storage property is never there, because none of those is a dwelling.

The fields that matter

Section 1003.4(a) lists what a lender records for each loan. For commercial reading these are the ones to know.

  • Action taken, (a)(8). The file includes requests that did not become loans. To count loans made, keep action taken 1, which is a loan originated. Loans a reporter bought from another lender carry a different code, so leave them out or you will count the same loan twice.
  • Loan amount, (a)(7).
  • Purpose, (a)(3): home purchase, home improvement, refinancing, cash-out refinancing or other.
  • Location, (a)(9): state, county and census tract of the property.
  • Occupancy, (a)(6): principal residence, second residence or investment property.
  • Number of units, (a)(31), and for multifamily the number of income-restricted units, (a)(32).
  • Interest rate, (a)(21), loan term in months, (a)(25), and combined loan to value ratio, (a)(24).
  • Business or commercial purpose, (a)(38): whether the loan was made primarily for a business or commercial purpose.

Lenders are identified by a legal entity identifier. See LEI.

Partial exemption. Under 1003.3(d), a bank or credit union that originated fewer than 500 covered closed-end mortgage loans in each of the two preceding years need not report a list of “optional data.” That list includes paragraphs (a)(15) through (30) and (32) through (38), so the rate, the term and the loan to value ratio can be blank for a smaller bank’s loans. The number of units, (a)(31), is still reported.

Looking for a lender now? Find lenders for this in your state or see Multifamily lenders state by state.

Reading the multifamily slice on this site

This site keeps the rows where a loan was originated on a property of five or more units and leaves manufactured-home parks out. For 2025 that is 43,226 HMDA, loans for $269B HMDA, . The year before it was 32,620 loans.

The table below covers 41,516 of the 2025 loans. That is fewer than the full count, because the table is built from the loan rows this site can show by size and leaves out rows held back by its display rules. The shares in the table are shares of the loans in the table.

Multifamily loans made in 2025, by loan size
Loan sizeLoansShareMiddle rateMiddle LTVRefinances
Under $1 million17,87843%7.01%66%45%
$1 million to $2.5 million9,90024%6.38%63%51%
$2.5 million to $5 million4,94712%6.17%63%54%
$5 million to $10 million3,2678%5.97%65%56%
$10 million to $25 million2,9057%5.75%65%54%
$25 million and over2,6196%5.45%64%53%

HMDA, Five or more units, manufactured-home parks left out. Rate and LTV are as filed under HMDA; a loan that reported none is left out of that median.

How to read the table:

Most multifamily loans are small. 43% HMDA, of the loans in the table were under $1 million and 79% were under $5 million. The middle loan was $1,200,000. A reader who pictures a multifamily loan as a $30 million agency execution is picturing the last row.

Rate falls as size rises. Read down the middle rate column. The smallest loans carried the highest middle rate. This is what was filed, across every kind of lender and every month of the year. It is not a quote, and a loan made in January and one made in December faced different markets.

Loan to value barely moves. The middle ratio sits in a narrow range in every band. The middle across all loans was 65%.

Blanks are left out, not counted as zero. A loan that reported no rate is not in that band’s middle rate. Because of the partial exemption, the loans with blanks lean toward smaller banks and credit unions, so the middle rate in the smallest band says less about small-bank pricing than the row suggests.

Worked example (hypothetical). You are placing a $1,500,000 refinance of a 20-unit building. The $1 million to $2.5 million row is your band. Suppose the row showed 10,000 loans and a middle loan to value of 62 percent. If the building is worth $2,300,000, a 62 percent loan is $1,426,000 ($2,300,000 times 0.62), so a request of $1,500,000 is 65 percent ($1,500,000 divided by $2,300,000) and sits a little above the middle of what was filed. That tells you the request is ordinary for its size. It does not tell you any lender will make it.

The investor 1-4 slice

A loan to an investor on a one to four unit rental is in HMDA when it is a purchase, an improvement loan or a refinancing. Filter on occupancy (investment property) and the business or commercial purpose field. This site counts 595,971 HMDA, such loans for $203B HMDA, in 2025. Bank call reports cannot split investor rentals from owner-occupied homes inside the 1-4 family line, so for this kind of loan HMDA is the better public record.

Where to get the data

  • The Bureau’s HMDA page links the public tools and files.
  • The HMDA Data Browser filters the national file by year, geography and lender and exports the rows.
  • Modified loan registers give one lender’s public file for a year.
  • Snapshot files are fixed national files for each year.

Under 12 CFR 1003.5(c) a lender must also give the public a notice, at its home office and branch offices in metropolitan areas, saying that its modified register is on the Bureau’s website.

What it cannot tell you

  • Lenders that do not report, and loans that are not dwelling-secured, are missing.
  • Construction loans are largely missing, because temporary financing is excluded.
  • No loan status. HMDA records the loan when it is made. It does not say whether it was later paid off, sold or modified.
  • No borrower. The public file does not name the borrower, and this site does not try to work one out.
  • Last year, not this quarter. The file is annual. A lender that made forty apartment loans in 2025 may have changed course since.
  • Not appetite. A count of loans made is a fact about the past. It is not a promise about the next request.

Questions to put to the lender

  • You made multifamily loans in this county last year. Are you still adding them, and at what size?
  • Do you hold these loans or sell them?
  • For a building of this size, which matters more to you, coverage or loan to value?
  • Is the rate you would quote today fixed for the term, and for how long?

Terms used here

Sources

Every rule and outside figure above comes from one of these, opened on . Dates are the source's own. Figures from this site's data carry their own source and date beside them.

  1. 12 CFR 1003.2, Regulation C, definitions (financial institution, dwelling, multifamily dwelling), retrieved .
  2. 12 CFR 1003.3, Regulation C, excluded and partially exempt transactions, retrieved .
  3. 12 CFR 1003.4, Regulation C, compilation of reportable data, retrieved .
  4. 12 CFR 1003.5, Regulation C, disclosure and reporting, retrieved .
  5. Home Mortgage Disclosure Act data (Consumer Financial Protection Bureau), dated .

Next step: check the record

Keep reading

Questions people ask

Are loans on office buildings or warehouses in HMDA?

No. Regulation C covers loans secured by a dwelling. A loan on an office building, a store or a warehouse is not reported, whoever makes it. For those, the public record is the balance a bank holds in its call report.

Does HMDA list every multifamily loan?

No. A lender reports only if it meets the rule's tests, which include making at least 25 covered closed-end mortgage loans in each of the two preceding years. Construction-only loans are left out as temporary financing. Loans by lenders outside the rule are not there.

Why do some multifamily loans in the file have no rate or loan to value?

Banks and credit unions that made fewer than 500 covered closed-end loans in each of the two preceding years are partially exempt. They need not report several fields, and the interest rate, the loan term and the combined loan to value ratio are among them.

Cite this

Source: The Lender Report, How to read HMDA data for multifamily and investor loans, https://lender.report/guides/how-to-read-hmda-data/, data as of November 11, 2026.

General information, not legal, tax or credit advice. A lender's own policy decides what it will do; ask it for the policy in writing.

Source and date appear beside each figure. Banks report balances, not loans made. Loans made come only from HMDA and SBA files. We do not audit filings and can make errors joining them. Report a problem