HMDA Rules-Threshold for Open-End Lines of Credit

Assuming a Financial Institution meets the 500 threshold for Open-End Lines of Credit, if the institution makes a large open-end line of credit to a builder for the purpose of constructing both spec and pre-sold homes, is the loan HMDA reportable under the new HMDA rules? For purposes of this question, assume the transaction is documented by a master line of $15,000,000 with sub-notes under the master line for each property being constructed. If the Financial Institution does not meet the threshold test, I assume the transaction would not be HMDA reportable. Do you concur?