Yes, the count for threshold purposes is based on the "new rules," but only includes "originations" of credit. However, if you are making the determination now or going forward, then you really shouldn't have to worry about the old rules because both preceding calendar years, i.e. 2018 and 2019, and anything thereafter would encompass data collection criteria for the "new" HMDA. But, yes, there are a few types of loans that would have to be counted under the new rules that would not have been counted under the old rules. The biggest category would be "Other," such as taking out a loan on a previously "free and clear" dwelling and using the funds for debt consolidation.