If you meet the applicable loan-volume threshold for closed0end-mortgage and open-end-lines of credit, do we stop collecting the DMI from our applicants?

By exempt reporters, I assume you mean you are no longer required to report under HMDA (as compared to qualifying for the partial exemption).

While non-HMDA reporters do not have to collect demographic information under Regulation C, they are still required to collect it under 1002.13 of Regulation B for each "application for credit primarily for the purchase or refinancing of a dwelling occupied or to be occupied by the applicant as a principal residence, where the extension of credit will be secured by the dwelling."

Reg B-only banks have the option to collect either just the categories of DI or the categories and subcategories of DI, for applicable applications.

We wont need to report until our volume of closed end loans reach 25 for two consecutive CY. So far for CY 2018 we have 14 closed end loans.

Okay. Then as I stated, you need to collect DI in accordance with Regulation B. If you were a prior HMDA bank and you think you will again be a HMDA bank within the next 5 years, 1002.5(a)(4)(iii) of Regulation B allows you to continue to collect DI in accordance with HMDA rules for up to five years (or whenever you become a HMDA reporter). This means that you can just keep collecting DI like you always did and not worry about the quirks of being a Reg B only bank - for up to 5 years or until you become a HMDA reporter again.

"(iii) A creditor that submitted HMDA data for any of the preceding five calendar years but is not currently a financial institution under 12 CFR 1003.2(g) may collect information regarding the ethnicity, race, and sex of an applicant for a loan that would otherwise be a covered loan under 12 CFR 1003.2(e) if not excluded by 12 CFR 1003.3(c)(11) or (12);"

Thank you.