We are a HMDA reportable FI.

We currently have 22 originated closed-end mortgage loans, and zero (0) open-end LOCs for the year 2024, with none in the pipeline for future closings this year.

If we finish out the year with just 22 originates, I will still do my reporting for year 2024 on or before March 1, 2025, but I will not have to report for years 2025 & 2026?

If we reach the 25 originated loans in 2025 & 2026, we will have to collect & report again starting in year 2027?

I want to make sure I get the years correct, and not miss reporting one.

It sounds like you are on the cusp of HMDA reporting. That must be exciting. ;-) Regardless of how many loans you originated in 2024, your 2024 reporting status is determined by 2022 and 2023. So, assuming you had more than 25 closed-end mortgage loans in both 2022 and 2023, you need to report for 2024. Now, if you don't hit the 25 mark in 2024, you are not required to report for 2025 or 2026, but may have to resume in 2027 (assuming you originated at least 25 closed-end mortgage loans in 2025 and 2026).

Here is the CFPB's HMDA Institutional Coverage Chart, which can help with determining HMDA applicablility: https://files.consumerfinance.gov/f/documents/cfpb_hmda-institutional-coverage_2023.pdf.

Thank you Adam, appreciate the clarification and the Coverage Chart link.