In the new FIG dated August 2018 that was just released, it is unclear what we should be reporting for rate spread if we are an exempt institution. On page 86, under Rate Spread, can I just report "Exempt" for all of our loans including loan applications that were closed for incompleteness, withdrawn, or denied? Or do, I have to report "NA" for loan applications that were closed for incompleteness, withdrawn, or denied and for loans that were originated or approved but not accepted, report "Exempt"?
It says "Enter "Exempt"" if, pursuant to the 2018 HMDA Rule, your institution is not reporting Rate Spread. So, does that mean, I can just copy and paste "Exempt" all the way down the LAR for that column or I just have to filter so I can paste in "Exempt" for originated and approved but not accepted, and "NA" for the rest?