HMDA/Section 1071 Question

I have a question about a SBDC exclusion. I know that the exclusions reference that HMDA reportable transactions are excluded. We are a non HMDA bank so what we initially thought based on the prior SBDC trainings I have been to and the research that we have done is that we would exclude transactions that would be HMDA reportable if we were a HMDA reportable bank. However, I recently went to a Forvis compliance conference and what I heard there caused some confusion for me in regards to that. We are a non HMDA bank due to us not having a branch in an MSA and not because of our loan volume. So their interpretation was that HMDA transactions would not be excluded for us since we don’t have a bank in an MSA and since our loan volume wouldn’t exclude us from HMDA if we were in an MSA. I can see following the citations how they derived to that answer but this is the first time I had heard it interpreted that way. Can you give any guidance or clarification on this?”