Answer:
No; the partial exemption creates an interim threshold for reporting depository institutions only. For example, a depository institution that originated 25 or more closed-end HMDA mortgage loans but few than 500 in each of the prior two calendar years can take advantage of this partial exemption from reporting certain fields on the HMDA LAR.
-----------------------------
Learn more about Kathleen Blanchard’s webinar
Implementing the Partial HMDA Exemptions - Get the Details