I just wanted to double check myself. For 2020 we only originated 73 closed-end covered loans and are below the threshold for open-end lines as well. Which means we do not have to submit HMDA data before 3/1/2021 and that we will not need to collect HMDA data for 2021 and 2022 for submittal. Is this interpretation correct?

If you only originated 73 closed-end covered loans in 2020, you won't be reporting for 2021 or 2022. To determine if you are required to report for 2020 (submission due 3/1/2021), you need to look at your originations in each of the two preceding calendar year, which would be 2018 and 2019. How many closed-end covered loans did you have in each of those two years?

Here is a coverage flow chart effective 7/1/20 through 12/31/21: https://files.consumerfinance.gov/f/documents/cfpb_2020-hmda-institutional-coverage.pdf

Oh okay that does make sense. Since we had 145 closed-end covered loans for 2018 and 109 for 2019 then we would report for 2020, but since we only had 73 closed-end covered loans for 2020 we would be exempt from reporting 2021 and 2022 data.

For some reason no matter how many times I read that section of the regulation it would just not click with me.

Thanks for your help.

In other words, if we originated 30 closed-end mortgages in 2018 but only 20 closed-end mortgages in 2019, then we do not need to report for year 2020? In year 2020, we originated less than 10 closed-end mortgages.

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.

Although we are exempt in filing, we are to prepare a letter to Re. HMDA Exemption for Year 2020 Submission. Where could I find the address we should be sending this letter to?

Not sure - I have never heard of such a letter. Usually you just either file or you do not. Do you have any more information concerning it?

Looking back at our records from previous years when we did not need to report HMDA, we sent the Federal Reserve Board a letter saying that we originated less than the certain amount of loans for that year's HMDA. Not quite sure if we still need to do this.

We are now exempt from reporting. Are we required to renew the banks LEI?

Do you sell any loans?

We do not sell loans

Then I can think of no reason to continuing to register.

If I am reading this correctly, I would not have to submit in 2022 thru 2023 since we originated 55 loans in 2019, 117 in 2020, and 81 in 2021. Correct?

Correct. In 2022, your two proceeding were 2020 & 2021. In 2023, your two proceeding will be 2021 & 2022. Therefore, the earliest you may need to submit would be the 2024 data in early 2025.

From the commentary to Regulation C:
5. Originations. Whether an institution is a financial institution depends in part on whether the institution originated at least 100 closed-end mortgage loans in each of the two preceding calendar years or at least 200 open-end lines of credit in each of the two preceding calendar years. Comments 4(a)-2 through -4 discuss whether activities with respect to a particular closed-end mortgage loan or open-end line of credit constitute an origination for purposes of § 1003.2(g).

For further reference, here is an institutional coverage chart for 2022 that can assist in determining coverage: https://files.consumerfinance.gov/f/documents/cfpb_2022-hmda-insitutional-coverage_03-2021.pdf