Here's our situation...

Bank 1 is a HMDA reportable bank that has been using the partial exemption because they have not been originating 500+ closed-in loans in previous 2 years.

Bank 2 has not been a HMDA reportable bank

When these 2 banks combine because of the merger/purchase I know that we will not have to include Bank 2's loans until January 1st of next year. My question is...
---When determining if we can still use the partial exemption, would we look at the numbers of loans for Bank 2 that would have been HMDA reportable?

example: 2019: Bank 1 (400 loans)... Bank 2 (200 loans)
2020: Bank 1 (375 loans)... Bank 2 (175 loans)

1. Combined for these 2 years they would not have qualified for the partial exemption so January 1st do we start reporting all fields?
2. Do we combine that numbers starting in 2020 or 2021 and count the prior 2 years from there? (2020-550 loans, 2021-600 loans so we would start reporting all fields in 2022?)

Hope that makes sense.

Yes- you need to start full reporting next year:

ii. Assume two institutions that are eligible for the partial exemption for closed-end mortgage
loans merge and the surviving or newly formed institution does not meet the requirements for
the partial exemption. Collection of optional data for closed-end mortgage loans is permitted but
not required for the calendar year of the merger (even though the merger creates an institution
that does not meet the requirements for the partial exemption for closed-end mortgage loans).
When a branch office of an institution that is eligible for the partial exemption is acquired by
another institution that is eligible for the partial exemption, and the acquisition results in an
institution that is not eligible for the partial exemption, data collection for closed-end mortgage
loans is permitted but not required for the calendar year of the acquisition.