Just verifying that I am correct.....if we claim small bank reporting exemptions, this includes denial reasons regardless of who is our regulator....which for us is the FDIC.

Unless you were previously under the OTS.

Ah......I thought I had read something about that recently, but couldn't remember exactly what. Thank you, Randy.

regardless of who is our regulator
The OCC also requires reasons for denial to be reported.

We are OCC regulated and we are reporting under the exemption. We are reporting the denial reasons since OCC mandates it. My question is for originated loans- under the denial reason do we still use the exemption code of 1111 or use code 10? thank you in advance

Well, you aren't really exempt from the reason for denial fields (per your statement that you are required by the OCC to report them), so you should use code 10.

That's what we figured. Thank you for the confirmation!