My FI had less than 25 loans for 2015 and we will not meet that threshold for 2016; we meet all other small entity requirements. So, after the 2016 reporting in 2017, we are done! However, if we went over that threshold for year 2020 then we would report in 2021, correct?Thanks for your help.

Yes, everyone must monitor and see if you exceed either threshold (open end and closed end once). Don't forget open end...both consumer and business purpose open end...to see if you exceed that threshold.

I would start a chart and keep adding on annually.

Thank you Kathleen!