The rules changed in July of 2020 that were effective for your 2020 submission (here in 2021). So, yes, you are correct that it appears that you don't need to submit closed-end HMDA for 2020 based on your 2018 and 2019 numbers. Based on your 2020 numbers, it also appears you won't be submitting for (at least) the next two years - 2021 and 2022.
The flowchart I shared above will help walk you through it.
Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.www.compliancecohort.com