I know that for purposes of reporting small business applications, HMDA reported loans are NOT included in the small business report.
Initially, I had thought the HMDA loans were also not included in the count of originations used to determine if we were a covered institution. But, on reading the CFPB Executive Summary again, I'm thinking I DO need to count HMDA reportable originations in determining if 'm a covered institution, I just don't report them.

Which seems contrary as, if I didn't report them, I wouldn't have 100 originations.

At this point, I'm going in circles.

"But, on reading the CFPB Executive Summary again, I'm thinking I DO need to count HMDA reportable originations in determining if 'm a covered institution, I just don't report them."

Where?

Took lunch and cleared my mind and read it one more time and answered my own question. I'd been thinking too hard. Under Covered Originations: "For purposes of determining institutional coverage . . . financial institutions count COVERED ORIGINATIONS. A covered origination is a covered credit transaction that the financial institution originated to a small business." Then, going to the Covered Credit transaction section: " . . . covered credit transactions can include loans, lines of credit, credit cards . . . However, the following transactions are excluded from coverage: Trade credit, HMDA REPORTABLE TRANSACTIONS . . ." I had it right in my mind the first time.

However, a business purpose loan secured by residential property that is not used to purchase or improve residential property and is not a refinance of a dwelling secured loan would be reported under 1071 if the borrower is a qualified small business.

Absolutely agree Len. Thank you.