It includes only originations and does not include denials, withdrawn, or approved but not accepted. The real challenge is counting which loans would count during 2017 (and 2016 if applicable) as the old rules and new rules don't fully align. Basically, for those years you have to report based on the number or originations that would have been reportable under the current/new rules.
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Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.
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