I'm working on determining if we are eligible for the partial exemption to the HMDA rules. We are so close to the threshold, that I need to be very precise in how it's calculated. I spoke to the CFPB about exactly how it was to be calculated 2 weeks ago, and they said it should be all closed end originations, regardless of whether they were reported (at that time) or not. It had nothing to do with reportability or LAR lines. Here's my question, which I did NOT ask her, but maybe someone else already did. And the answer to this will determine if we are exempt or not.
Do originations that we did, that we did NOT make the credit decision for (PHFA, for example) count into the 500? It was an origination, and it meets the closed end mortgage definition.... So I am inclined to say that yes, it counts. Thoughts?