If we originated less than 500 loans in the past two years for closed-end, are we exempt from reporting HMDA?

No. There are two separate loan-volume exemption thresholds for HMDA reporting:

• Institutional Coverage – The loan-volume threshold determines whether an institution is required to report HMDA. If an institution originated fewer than 100 closed-end mortgage loans or 500 open-end lines of credit in either of the two preceding calendar years, they are not required to report HMDA data.
  
  
• Partial Exemption - This exemption applies only to depository institutions and reduces the number of data points / data fields that are required to be reported.