So to qualify for the appeal process in the final rule published by the CFPB yesterday, the creditor would still have to meet the asset test, is that correct? I want to make sure I am thinking correctly that an institution over $2 Billion in assets would not be eligible for this exemption.

Approximately correct. The asset cap is slightly more than $2 billion. It varies annually based on CPI changes. In 2016, and in 2017 for applications received before April 1, 2017, the cap is $2.052 billion.