My FI is trying to clarify what is considered an "origination" to determine if we now fall under the 25 closed-ended for reporting threshold, not data reporting. We currently voluntarily report regardless, but wanted to know if we are doing it as a requirement now or still voluntarily.

12 CFR 1003.3(c)(11) A closed-end mortgage loan, if the financial institution originated fewer than 25 closed-end mortgage loans in either of the two preceding calendar years; a financial institution may collect, record, report, and disclose information, as described in §§ 1003.4 and 1003.5, for such an excluded closed-end mortgage loan as though it were a covered loan, provided that the financial institution complies with such requirements for all applications for closed-end mortgage loans that it receives, closed-end mortgage loans that it originates, and closed-end mortgage loans that it purchases that otherwise would have been covered loans during the calendar year during which final action is taken on the excluded closed-end mortgage loan;"

My understanding is that if we originate (not including the purchases, withdrawals, denials) 25 closed-ended mortgage loans, then we are now required to report for HMDA. When reviewing the HMDA transactional coverage document that was released by CFPB it emphasizes that it's "originated covered loans."

Can someone confirm if I'm looking at this the right way? That it is 25 originated closed-ended mortgage loans (excluding purchases, withdrawals, or what would normally be considered a HMDA reportable loan under data reporting context) that would trigger the requirement.

You are correct. You only count originated (closed) covered loans.

Great, thank you for confirming. There was some disagreement between the definition to determine this. Much appreciated!