Your 2019 count means you are exempt for 2021. The word "either" means just what it says -- For 2021, if you originated fewer than 200 dwelling-secured open-end lines of credit in 2019 or in 2020, you are exempt.
For the rule to mean otherwise, it would have to say, "unless you originated 200 or more dwelling-secured open-end lines of credit in either of the preceding calendar years, you are exempt," or something similar.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8