Well, they may be. But that is only one criterion of four that must be met in order to be qualified for the exemption. Review Regulation Z section 1026.35(b)(2)(iii), paragraphs (A), (B), (C) and (D). The $2 billion figure in para. (C) was increased to $2.028 billion for 2014 and $2.06 billion for 2015. But you have to meet all four criteria to qualify.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8