The LEI is part of the Universal Loan Identifier (ULI) and I believe that the ULI is part of the Freddie Mac and Fannie Mae Phase 3 updates of the Uniform Loan Delivery Dataset (ULDD) with an Application Received Date on or after January 1, 2019 and for delivery on or after the May 20, 2019 mandate. I don't think that just because your entity might be exempt from HDMA reporting that the ULI is going to be optional.
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