Our bank assets total $1.4 billion as of 1/1/25. In 2023, we originated approximately 260 open-end mortgages and 175 closed-end mortgages that were HMDA reportable. In 2024, we originated approximately 260 open-end and 190 closed-end mortgages that were HMDA reportable. I have not been keeping up on Reg C changes over the past couple of years, so I have a couple of questions that I am hoping you can give me feedback on:

1) Based on the information above, do we qualify for the partial reporting exemption for 2025?

2) A larger bank will acquire our bank in Q3 of this year. The total assets between them and us will be approximately $8 billion. The larger bank reports all fields. Assuming we can report 2 separate LARs for 2025, and that our bank currently qualifies for a partial exemption (referring to question #1), when must our bank start collecting all HMDA fields?

THANK YOU in advance for your help!!

Based on what I read last year, these are my answers:

1) Yes, we qualify for partial exemption for 2025 based on asset size and loan volume.
2) If the acquisition closes in Q3 2025 and we report a separate LAR for 2025, we can use the partial exemption for that year. However, we must start collecting ALL HMDA fields starting January 1, 2026, for 2026 reporting, under the new ownership of the larger bank.

Could some of you confirm this is correct based on current Regulation C?

Thank you!

1. Partial exemption is base on volume. Since you originated fewer than 500 closed end loans in each of the previous 2 years you do qualify for the partial exemption.

2. This will depend on when the acquisition takes place. Once your FI is absorbed by the acquiring FI and they are the survising FI then you must collect under their requirements for loans originated from that date forward. Your FI will no longer have the partial exemption because it will cease to exist.