My question relates to open-end lines of credit.

if the FI originates at least 500 Open-End LOC, does that also have to be that the 500 are HMDA reportable or just in general 500 originated?

does that also include any Open-End LOC that received adverse actions? (denied, withdrawn, ABNA, or CFI)

I am wondering if we need to report them or not.

1003.3(c)(12) does not refer to "covered" open-end lines of credit.