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Turning Market Shifts into Growth Opportunities with 2024 HMDA Data

By Bernard Nossuli posted 05-07-2025 12:49

  

Each year, the release of HMDA data provides new insight into how the mortgage landscape is evolving. The 2024 data reveals early signs of recovery from the challenges of 2023, with a notable rebound in refinance activity and continued shifts in market leadership. For credit unions, these trends offer both a reality check and a strategic opportunity: competition is rising, but there is room to grow by leaning into mission-driven lending and deepening service to members.

Loan Volumes Are Rebounding, but Affordability Pressures Remain

In 2024, U.S. lenders originated 4.9 million purchase and refinance loans totaling $1.67 trillion in volume, a modest increase from 2023. Refinances fueled much of the growth, surging by 63% in dollar volume from the previous year and claiming a larger share of overall activity.

At the same time, the average loan size continued to climb, reaching nearly $340,000. This uptick reflects ongoing affordability challenges, as rising home prices and high rates increase borrowing costs.

For credit unions, these dynamics underscore the need for flexible products, competitive pricing, and proactive member education to help buyers navigate affordability barriers.

IMBs Extended Their Lead, but CUs Hold Important Ground

Independent mortgage banks (IMBs) captured 65.4% of all purchase and refinance loans in 2024, further expanding their dominance even though they make up only 18% of HMDA-reporting institutions. This trend signals intensifying competition, especially in the purchase market.

Yet, credit unions continue to have a meaningful presence. A new analysis of the top 20 credit unions by volume shows that many are successfully expanding their reach, especially in historically underserved markets (shown in the MMCT and LMI columns below).

Top 20 Credit Unions By Loan Count, 2024

Credit unions that focus on mission-driven lending and community engagement have an opportunity to differentiate themselves in a crowded field increasingly shaped by scale and consolidation.

Denial Rates Highlight Both Progress and Gaps

Denial rates ticked upward in 2024, with debt-to-income (DTI) ratios remaining the most common reason for denials across all racial and ethnic groups. However, there were differences by lender type: while banks and credit unions managed to lower their denial rates slightly, IMBs saw a modest increase.

This is a bright spot for credit unions, which traditionally prioritize member service and flexible underwriting. But disparities persist. For example, Black borrowers continued to face an 18% denial rate for purchase loans compared to just 9% for non-Hispanic white borrowers.

Closing these gaps will require intentional strategies that balance risk management with a deeper understanding of diverse member needs.

The Market Is Becoming More Concentrated

The top five lenders accounted for nearly 20% of all loans and dollars originated in 2024, up from about 18% the year before. This consolidation trend means that smaller lenders—including many credit unions—must be strategic to maintain market share.

Top 25 Lenders By Loan Dollars, 2024


Targeted growth strategies, local expertise, and member-first service models will be crucial competitive advantages for CUs navigating a market increasingly dominated by a few major players.

Turning Insights Into Opportunity

The 2024 HMDA data paints a complex picture: modest recovery amid persistent affordability pressures, equity gaps, and competitive shifts. For credit unions, the data offers a roadmap:

  • Benchmark performance. Use HMDA and local market data to see how your CU compares to peers and where gaps or growth opportunities exist.
  • Expand reach in underserved areas. Credit unions that increase lending in majority minority census tracts (MMCT) and low- to moderate-income (LMI) neighborhoods can fulfill their mission and capture untapped demand.
  • Prioritize equitable lending. CUs can help close homeownership gaps and grow sustainably by continually refining underwriting and outreach strategies.

At iEmergent, better data drives better decisions. With tools like Mortgage MarketSmart, credit unions can turn HMDA insights into action, empowering more members on the path to homeownership and strengthening their communities.

To see more insights—like application volumes and breakdowns, additional denial trends, diverse lending insights, and more—view our detailed 2024 HMDA data analysis

To learn more about how Mortgage MarketSmart can help your CU grow smarter, visit www.iemergent.com.

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