HMDA Rate Spread "Exempt" or "NA"

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can I just report "Exempt" for all of our loans including loan applications that were closed for incompleteness, withdrawn, or denied? Or do, I have to report "NA" for loan applications that were closed for incompleteness, withdrawn, or denied and for loans that were originated or approved but not accepted, report "Exempt"?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?

The way i'm reading it, you can just report "Exempt", but it's a good question.

If you are exempt from reporting that field then you report Exempt. NA would be for those non exempt FIs to report those loans that are not subject to rate spread reporting such as a business purpose loan.

Great, thanks for the responses.

To clarify, while you can report Exempt for all rate spread data points as others said, you technically have the option (system pending) to do both: report Exempt and NA if you choose. I really can't see a reason why you wouldn't want to just list Exempt every time, but voluntarily reporting data points is technically permissible.

From the ruling:
"Accordingly, the HMDA platform will continue to accept submissions of a data field that is covered by a partial exemption under the Act for a specific loan or application as long as those insured depository institutions and insured credit unions that choose to voluntarily report the data include all other data fields that the data point comprises."

From an examiners perspective, "exempt" would be correct. If other entries are made and are incorrect (it happens) those could be violations. Why tempt fate?

Exactly, Andy. There is no point in risking errors when you can avoid them altogether.

I agree. I'm encouraging clients to collect, but not report, several things: DTI, LTV and credit score. These can be used as "defensive" information to explain why someone was denied or given a higher rate. However, I would report "exempt" on everything possible. You can't go wrong.