When looking at the reporting threshold for open-end credit in 2018, which loans should be included in this count?

Do I look at all open-end credit originated in 2016 and 2017 to determine if we report these? Or do I look at only those secured by a dwelling?

Nevermind, sorry... found my answer:

(o) Open-end line of credit means an extension of credit that:

(1) Is secured by a lien on a dwelling...

I know you found the answer, but you also need to understand the exemptions. The 2018 institutional coverage test applies the new loan/line rules and new exemptions, yet you look back at 2016 and 2017. In other words, you can't just look at the LAR for those 2 years to determine if your institution is subject to HMDA in 2018 as the exemptions and coverage requirements have changed.

Thanks David. So here is a dumb follow up question -

If I am looking at my lines of credit, would I only count the lines that would be HMDA reportable in 2018 to see if we meet the threshold for reporting these?

Say I have 90 HELOCs and 25 commercial lines of credit secured by a dwelling in 2016. Would this require me to report lines of credit, or do I need to see how many would actually be reported and use that as my count?

You have to look at what the lines are for - using the 2018 coverage rules and exemptions. For instance, fi the commercial LOC's are used to purchase or improve a dwelling, they are covered by HMDA (unless there's another exemption). If they are business equity (use a dwelling as collateral, but the purpose is for payroll/business operating expenses), it is not covered by HMDA. If you have over 100 "covered" LOC's for 2 years in a row, then you are to report all covered LOC's in the next year.

OK, thank you! I appreciate your help!

My volume of HELOCs hovers right at the threshold - sometimes above or below the 100 by only a few loans. If we have over 100 in 2017 & 2018, we collect & report in 2019. But if we have less than 100 in 2019, then we DON'T report in 2020 (because both of the prior 2 years (2018 & 2019) did not exceed the 100, correct? So, our reporting will be sometimes yes and sometimes no for HELOCs based on the 2-year reporting threshold. Although I see from the new proposal today that we may optionally report HELOCS anyway - which we probably won't do.

Correct. Nor would you report in 2021. You have to be over the limit for 2 years. Thus, one year below the 25 or 100 threshold, takes you out of reporting for 2 years (for that type - loans or lines, or both).