Hi everyone. I have heard from sources and a couple of reads on the internet that we only have to cound closed-end loans when we are calculating our numbers for the small servicer exemption. I don't find that anywhere in the reg and I haven't seen it anywhere in the threads. But some folks insist that you don't have to include HELOC in the totals.Can anyone please clear up my conundrum?

The answer is in the definition of "mortgage loans" that is in the beginning of the Mortgage Periodic Statements section. See the last sentence of the section below.

1026.41 Periodic statements for residential mortgage loans.

(a) In general. (1) Scope. This section applies to a closed-end consumer credit transaction secured by a dwelling, unless an exemption in paragraph (e) of this section applies. A closed-end consumer credit transaction secured by a dwelling is referred to as a mortgage loan for purposes of this section.