Based on what you've shared, yes, you will be exempt on 7/1/20. And, since your 2019 originations were at 85, you'll also be exempt in 2021 (2020 data won't matter because you were below 100 in 2019). 2022 will be dependent on TBD 2020 and 2021 data. If you are under 100 originations in either, you'll continue to be exempt and you 'll continue that game going forward, look back 2 years, if under 100 in either you're out, 100 or more in each, you're in. I also agree with your take, since you only have a small cushion, you'll want to continue to track your originations.