Answer:
Small credit status is determined by where you make your loans and not where your branches are located:
“During the preceding calendar year, the creditor extended over 50 percent of its total first-lien covered transactions, as defined in § 1026.43(b)(1), on properties that are located in counties that are designated either ‘rural’ or ‘underserved,’...”
[Editor's note: Beginning January 1, 2014, that provision is amended to read “During any of the three preceding calendar years,....”]