The inherent limitation of the HMDA  3/4  data collection must be understood if it is to promote market efficiency and legal compliance. It is not intended to discourage lenders from entering or remaining in higher risk segments of the market. Ultimately, the cost of credit to higher-risk borrowers is lower when there is a competitive marketplace.
I am convinced that when central banks and governments take up the tasks that are before them then we will surmount the difficulties our economies are experiencing. But this is no time for complacency in any respect.