Every credit union with a mortgage book files HMDA. That's 1,500+ credit unions. Most file it, submit it, and move on.
That is understandable. HMDA has long been treated as a compliance requirement. But the same data is also one of the most complete public records of the U.S. mortgage market: applications, originations, denials, loan purpose, product type, pricing, income, race, ethnicity, age, property type, lien status, lender, geography, and more. For credit unions, HMDA can answer a question internal reports cannot answer by themselves: How are we performing in the market we actually serve?
Your own production numbers tell you what happened inside your institution. HMDA puts those numbers in context: your peers, the IMBs and banks competing in your footprint, the borrowers being served or missed, and the products actually being used in your market.
Here are seven ways credit unions can put HMDA data to work in 2026.
1. Size the market inside your field of membership
Start with a basic but often unanswered question: How large is the mortgage market we are eligible to serve? HMDA lets you look at application volume, closed loan volume, and dollar volume by state, MSA, county, ZIP code, or Census tract. For credit unions, that means you can size the mortgage market inside your field of membership, branch footprint, or strategic growth markets. This helps you gauge where you stand relative to the market. If your originations are flat but the market is down, you may be holding share. If your originations are flat while applications in your footprint are growing, the market may be moving without you.
HMDA also helps measure pull-through: how many applications become closed loans. Comparing your pull-through to peer credit unions and other lenders in your market can point to practical questions about borrower readiness, underwriting fit, product mix, pricing, and follow-up.
2. See who's winning in your footprint
HMDA names the lenders active in your market. That is one of its most practical uses. Credit unions can see which institutions are winning purchase volume, refinance (rate and term vs. cash-out) volume, FHA loans, VA loans, home equity activity, manufactured housing loans, and more. This often clarifies strategic debates. If a national IMB is taking purchase share in your branch footprint, that is not just a marketing issue. It may be a product, channel, pricing, speed, or loan officer coverage issue.
HMDA helps move the conversation from “we need more loans” to “where are we losing share, to whom, and in which borrower or product segments?”
3. Compare your product mix to the market
Your portfolio mix is not always the same as your market’s demand mix. HMDA helps credit unions compare their own production against the products borrowers are using in the markets they serve: conventional, FHA, VA, USDA, jumbo, manufactured housing, Non-QM.
That comparison can be revealing. If FHA is a meaningful share of purchase lending in your MSA but only a small share of your own originations, you may be ceding entry-level homebuyers to other lenders. If VA lending is strong in a market with a military presence and your share is low, that may be a member-service opportunity. If manufactured housing is material in rural or exurban areas, it may deserve a separate strategy rather than being treated as an edge case.
For Non-QM, the same logic applies. HMDA does not include a public Non-QM flag, but Polygon Research applies a loan-level Non-QM classification methodology to identify likely Non-QM lending patterns by geography, lender, borrower profile, pricing, and loan characteristics. That can help credit unions evaluate whether there is a real opportunity among self-employed members, contract workers, investors, or borrowers with nontraditional income.
4. Understand borrower qualification pressure
HMDA also helps credit unions see how borrowers are qualifying — or failing to qualify — in their market. Borrower Income, loan amount, CLTV, co-applicant presence, denial rates, and denial reasons all tell part of the story.
For example, a market where most purchase borrowers rely on co-borrowers is structurally different from a market where single-applicant loans are more common. That has implications for underwriting, household income, member relationships, and borrower education. Denial reasons are especially useful. If denials are driven by debt-to-income ratio, the market may need different affordability interventions than a market where denials are driven by credit history, collateral, or incomplete applications.
When you compare denial rates, look and understand what is behind them.
5. Find overlooked member opportunities
Some of the most useful HMDA questions are not the obvious ones. For example:
- Where is home equity being extracted in your footprint, and which lenders are capturing that activity?
- How much cash-out refinance or HELOC activity is flowing through national banks or IMBs instead of community-based institutions?
- How much manufactured housing lending is happening, and is it being financed as real-property mortgage credit or chattel lending?
- Where is Non-QM activity concentrated, and what borrower profiles are associated with it?
These are member opportunity questions. They help a credit union see where borrowers in its own geography may already be using mortgage products but not from the credit union.
6. Measure shopping behavior and competitive exposure
HMDA can also help credit unions understand whether borrowers in their market are shopping. Polygon Research’s Borrower Shopping Index (BSI) measures whether borrowers in a geography appear to be getting multiple mortgage quotes or accepting the first offer in front of them. A higher BSI means more shopping behavior. That can feel like a threat because borrowers are actively comparing lenders. But it is also a competitive opportunity. If members are shopping, the credit union has a chance to be in the consideration set. In some markets, the most practical intervention may not be a new product or a pricing change. It may be showing up earlier, educating members to compare offers, and making sure the credit union is one of the lenders they include.
For credit unions, that is a natural role: help members shop with confidence, not just hope they come back before closing.
7. Measure the affordability pressure in your market
Affordability is not the same problem in every market. In one community, the issue may be the monthly payment. In another, it may be the down payment. In another, borrowers may have enough income but too much debt to qualify. In higher-cost markets, the loan size itself may be the barrier. Those differences matter because the solutions are not interchangeable. A rate buydown, down payment assistance partnership, portfolio product, borrower education effort, debt counseling program, or targeted outreach campaign each solves a different problem. Most credit unions cannot fund every possible intervention at once.
The Polygon Affordability Index helps break affordability pressure into the underlying drivers: rate, down payment, debt-to-income, loan size, and income. That gives leadership a clearer way to decide where to focus first in the communities they serve. HMDA-backed affordability analysis helps move the conversation from “affordability is a challenge” to “this is the affordability challenge we are trying to solve.”
Using HMDA Well
HMDA is an annual dataset. That is the real constraint. But within each reporting year, it is one of the most complete public records of mortgage lending activity in the United States. It shows applications, originations, denials, product type, pricing, borrower characteristics, property type, geography, and lender at the loan-level. For credit unions, the opportunity is to stop treating HMDA as a file that gets submitted and start using it as a market map. That is what HMDAVision was built to do: make the drill from market-level question to lender-level answer take a fraction of a second instead of weeks.
For ACUMA members, the ACUMA Benchmark Report is built on HMDA LAR and individualized for your credit union and peer set. It is available through ACUMA.
For credit unions that want to go deeper, Polygon Research also offers additional resources:
- Weekly free mortgage market data charts with commentary: www.polygonresearch.com/data
- Free Non-QM insights by state: https://www.polygonresearch.com/non-qm-market
- Polygon Affordability Index scores for the 50 largest U.S. housing markets: https://www.polygonresearch.com/affordability-index
- Data analytics training through Polygon Academy: https://academy.polygonresearch.com/
- Webinar replay: From Zero to Operational — How Hudson Valley Credit Union Built a Fair Lending Program in 12 Months: https://creditunions.polygonresearch.com/ACUMA-InsideTrack-March-18
HMDA is not just something credit unions report. Used well, it is a market map.
Val Buresch, CMB, CMCP - Founder & CEO of Polygon Research