The publication of the 2025 Home Mortgage Disclosure Act (HMDA) Snapshot on June 23, 2026, offers the industry its latest view of the mortgage market. These annual releases are typically used as a regulatory dataset, a market share reference point, or a way to compare one lender with another. Each of those serves an important purpose, yet they overlook many of the insights embedded within millions of rows of data. HMDA data can help lenders identify where borrower demand is shifting, where growth opportunities may be concentrated, and where patterns related to fair lending and the Community Reinvestment Act (CRA) are worth investigating.
Most HMDA analysis begins at the aggregate level or by sorting records through standard reporting fields: loan purpose, occupancy type, lien status, geography, action taken, pricing, and so on. That process is well suited to compliance reporting, peer benchmarking, and broad market description; however, it can also flatten the borrower story by focusing more on institution and product.
A borrower-centric analysis approach can help institutions move from broad monitoring to addressing more targeted questions:
- What kind of borrower is this, and what is that borrower trying to accomplish?
- Where do comparable applicants appear to receive favorable outcomes?
- Which competitors are the strongest among applicants that look like ours?
- Which institutions are the best acquisition targets in a new market?
- Where is deeper fair lending or CRA analysis warranted?
To demonstrate this borrower-centric perspective, first, we examine HMDA-reported national trends across seven borrower segments through the 2025 snapshot. Next, we narrow the focus to a single local market to establish how borrower characteristics and outcomes differ across segments. Finally, we introduce a borrower-centric opportunity framework that compares a selected lender’s portfolio to comparable applicants served by other lenders in the same market. Collectively, these examples illustrate how HMDA can evolve from a regulatory reporting dataset into a practical marketing intelligence framework.
The Market Has Stabilized, But Borrower Demand Is Fragmented
Figure 1 illustrates this dynamic using a segmentation framework. It is well understood that mortgage applications fell sharply from 2021 through 2023 and recovered only modestly by 2025. The more meaningful takeaway, however, is not simply that the market contracted as interest rates rose and then stabilized. Rather, it is that the composition of demand changed materially depending on the borrower’s situation.
Figure 1. National Borrower Segment Trends, 2021–2025
When the market is viewed through the borrower’s perspective, the patterns become more meaningful. Applicants seeking non-cash-out refinances (Rate/Term Opportunists) fell from 32.3 percent of applications in 2021 to 5.9 percent in 2023, before rebounding to 12.8 percent in 2025. Applicants tapping home equity (Equity Seekers) moved the other direction, rising from 24.3 percent in 2021 to more than one-third of applications from 2022 through 2025, becoming the largest segment nationally, as property values increased. Homebuyers also became relatively more prominent as refinancing receded.
The borrower-centric framework can provide management teams with a clearer view of where demand may be durable. For compliance teams, it provides a better starting point for asking whether a lender is serving changing borrower needs consistently across segments and markets.
Borrower Segments Behave Differently – Even Within the Same Market
Once the market is viewed through the lens of borrower situations rather than reporting categories, the next question is whether those segments actually behave differently in practice.
To illustrate the approach, Figure 2 turns to the New Orleans-Metairie, LA Metropolitan Statistical Area (New Orleans MSA), where borrower segments reflect meaningfully different borrower profiles and mortgage funnel outcomes. Denial rates, fallout rates, pricing, income, debt-to-income ratios, and leverage differ substantially across segments. Mainstream Homebuyers look very different from Constrained Homebuyers. Rate/Term Opportunists differ from Equity Seekers beyond product choice. Affluent Borrowers and Investors operate under different borrower economics altogether.
These differences matter strategically because aggregate comparisons can hide where opportunity is concentrated. It also matters from a compliance perspective because segments that are harder to serve may produce different patterns in approval rates, pull-through, pricing, and market coverage. Those differences do not, by themselves, indicate a compliance concern. They can, however, help lenders identify where a fair lending review, CRA planning, or a closer examination of market penetration may be warranted.
Figure 2. Borrower Segment Profile – New Orleans MSA
From Peer Benchmarking to Borrower Opportunity
The borrower-centric approach is more than an alternative way to label the market. It adds a different benchmark.
Traditional HMDA benchmarking often asks how a lender performs relative to peers defined by objective criteria or subjective decisions. A borrower-centric approach asks a different benchmarking question: where are comparable applicants – those with similar observable profiles as the lender’s portfolio – going if they are not going to this lender? The answer to this question defines opportunity in borrower terms, not just product or institution terms. A lender’s practical market opportunity is not determined solely by comparisons to selected competitors with varying business models. The opportunity also represents comparable applicants across all competitors in the same market.
Figure 3 illustrates this shift in perspective. The subject lender – an institution ranking within the top 10% of all institutions by applications in the New Orleans MSA in 2025 – was heavily concentrated among borrowers seeking to extract home equity. Its matched opportunity pool, however, tells a different story. Comparable applicants in the same market who obtained financing elsewhere were much more concentrated among homebuyers and rate/term refinance borrowers. This comparison suggests the lender’s current presence is more concentrated in home equity lending than the broader mix of lending opportunities available within its market.
Mainstream Homebuyers provide the clearest opportunity from this perspective. They combine a large opportunity signal with favorable borrower experience at the subject lender. Relative to comparable applicants served by its competitors in New Orleans, the lender shows lower denial and fallout patterns for this segment, as well as lower pricing. That combination suggests more opportunities exist and the lender already appears capable of competing for them effectively.
Rate/Term Opportunists also stand out as a significant opportunity, though for a different set of reasons. This segment contains a large pool of applicants whose characteristics closely align with the lender’s current customer base. At the same time, borrower outcomes are more mixed, with denial rates exceeding those of competitors serving similar borrowers.
Following Comparable Applicants Through the Funnel
Figure 4 extends the same logic from broad segments to borrower cohorts. The framework can follow comparable applicants through denial, fallout, and pricing outcomes across race and ethnicity, age, sex, income, and geography.
The recurring pattern is notable. Across many cohorts, the subject lender shows lower denial and fallout patterns than comparable applicants served elsewhere; however, pricing is higher and sometimes materially so. The magnitude of these differences also varies across borrower cohorts, suggesting the lender’s relative competitive position is inconsistent across groups of similarly situated applicants. For example, while the lender’s Denial Index is consistently lower than 100 across racial and ethnic groups – meaning the lender is less likely than competitors to deny comparable applicants in those groups – the index for Black/African American applicants (93) is materially higher than that of White applicants (53), suggesting the lender’s relative performance compared to competitors may warrant additional review.
This pattern does not establish a fair lending issue by itself. Instead, it identifies where additional context and deeper review may be warranted, from both a compliance and competitive perspective: If the lender consistently outperforms competitors for some borrower cohorts but not others, targeted analysis may be useful to better understand the underlying business, operational, or compliance drivers.
An Expanded Use of HMDA Snapshot Data
The 2025 HMDA Snapshot is more than a dataset. It is an invitation to analyze the mortgage market in a way that is both more strategic and more borrower-centered. This approach focuses on market opportunity and borrower experience; however, the same framework can extend further, to include a more refined segmentation and investigation of the root causes of excess denials and fallout. The basic framework, however, remains the same: follow comparable applicants through the mortgage funnel to uncover new opportunities.
For institutions willing to look beyond summary statistics, the 2025 HMDA Snapshot offers an opportunity to see not only where the market stands today, but also where their opportunity pools point to the next strategic question.
Figure 3. Borrower Opportunity Profile
Figure 4. Relative Borrower Experience by Cohort
Contact CrossCheck to discuss how your institution can use HMDA data to uncover actionable insights that support growth, fair lending, and regulatory compliance.
Authored by Jonathon Neil
Learn More
- Visit CrossCheck’s HMDA Hub
- Explore our HMDA compliance service offerings
- Read HMDA Compliance: Navigating the “Not Applicable” Maze
