Were are exempt from the expanded 2018 HMDA data requirements. Are we required to report rate spreads if they meet the HMPL thresholds? Or is this a voluntary option?

The "Rate Spread" Data Point is covered by the Partial Exemption. So, if you qualify for the partial exemption, then you could use "Exempt" in the corresponding Data Field (59). Not sure what you are asking about vis-a-vis the HPML threshold.

If you are a small filer then the entire field is optional (not just the new calculation method). In other words, you do not have to revert back to the previous rate spread reporting process.

I agree that the rate spread is exempt. On the surface, this seem strange as the partial exemption was supposed to roll back Dodd-Frank changes/burdens but the rate spread is a field that was required well before Dodd-Frank.

To explain this, we need to understand that the partial exemption rolls back two things: 1) New data points/fields and 2) data fields/points that saw an increase in burden because of Dodd-Frank. Basically, the partial exemption is attempting to take the HMDA burden for small filers back to where it was prior to Dodd-Frank.

Here is how I explained it in my training manual on the partial exemption:

"While the CFPB guidance isn’t extremely clear on this, it appears that the rate spread was included in the exempt data points because the 2018 version of the rate spread is more burdensome than it was under the prior rules - and the CFPB doesn’t appear to want to revert the rate spread requirements back to how they were previously, at least not at this time. To explain, the prior rules only required a financial institution to report the rate spread on Higher Priced Mortgage Loans (HPMLs) while the current rules have expanded the rate spread requirement to more loans than just HPMLs. Since the current rules are more burdensome, the CFPB probably had a choice to either exclude this data point or to revert it back to how it was pre-2018. Though it appears they chose to exclude this data point for now, it is also important to understand that the CFPB might change this requirement in the future. Specifically, footnote 34 of the CFPB interpretive and procedural rule states that the CFPB may eventually use their HMDA authority to bring back the rate spread for those institutions that utilize the partial exemption, though that would happen in a future "notice-and-comment rulemaking."