Chart of the Week: 2025 HMDA Respondents

Source: MBA; 2021-2025 Home Mortgage Disclosure Act (HMDA)
A total of 4,658 companies reported lending activity under the Home Mortgage Disclosure Act (HMDA) in 2025, according to MBA’s analyses of the dataset. Company types are defined by primary regulator and balance sheet assets, with large depositories holding assets of $10 billion or more.
Large depositories – historically, the smallest group of HMDA reporters – numbered 129 in 2025, flat from 132 reporters in 2024. Similarly, large depositories’ share of all HMDA reporters was flat at 2.8%. Though small in number, large depositories hold the second-largest market share, originating 14.5% of all home purchase loans and 10.7% of all refinance transactions in 2025. Large depositories lost market share for the third year in a row, and their share of both the purchase and refinance market fell by more than any group last year – a drop of 1.1% for purchases and 0.2% for refinances.
Community banks – by contrast, the largest group – were flat in number from 2,388 in 2024 to 2,378 in 2025. Community banks are now approaching the large depositories in terms of market share. In 2025, their share of purchase originations volume was only 0.6% less than the large depositories. For refinances, community banks fell short of the large depositories by only 0.2% in market share, narrowing the margin between these groups over the past three years. Overall, community banks hold 12.9% of the market – less than half a percent behind the large depositories at 13.4% – and are poised to become the second largest group of originators in the coming years.
Credit unions saw a slight dip in number in 2025 and, at 1,444 strong, were the second largest group, making up 31.0% of HMDA reporters. Though large in number, credit unions remain the smallest originators. The credit unions gained share of the purchase market but lost share of the refinance market in 2025. After two years of losing share of the purchase market, the credit unions reversed course and picked up 0.4% share in 2025. Their 6.6% share of the refinance market marked the second year of declines since their peak of 9.1% in 2023.
Non-depositories (IMBs), at 707 reporters, saw the largest decline in number of any group for the second year in a row in 2025. Representing less than one-sixth (15.2%) of HMDA respondents, the IMBs again originated 65% of all loans last year. After losing market share for the first time in many years in 2022, the IMBs reversed course and posted gains in both 2023 and 2024 before slipping slightly in 2025.
MBA’s HMDA data analyses focus on 1-4 unit, closed-end (or exempt), 1st lien loans originated through the retail/consumer direct, broker wholesale, or non-delegated correspondent channels. They exclude home improvement loans and loans with “other” or “not applicable” purposes. MBA publishes its own analyses in mid-summer, after scrubbing the dataset of errors and outliers and allowing reporters time to correct and resubmit their data.
Please visit MBA’s HMDA webpage to view our suite of standard HMDA reports and explore custom reporting options. Our HMDA Residential Originations Databook(with 2025 data) is currently available for purchase, and our HMDA Executive Databook is FREE for MBA members.
- Jon Penniman (jpenniman@mba.org)
