We originate more than 500 closed end mortgages, but we don't originate more than 500 open ended lines. I just want to verify, we are partially exempt only for open ended lines? And we can report the reduced data for open-end lines only?

There are two separate tests for the partial exemption – closed-end and open-end. 

• If you originated less than 500 closed-end mortgage loans in each of the two prior calendar years, you are subject to the partial exemption and reduced reporting requirements.
  
  
• If you originated less than 500 open-end mortgage loans in each of the two prior calendar years, you qualify for the partial exemption and reduced data requirements.

However, it is also important to note that the full exemption for open-end lines of credit is also 500 originations. If the financial institution originated fewer than 500 open-end lines of credit in either of the two preceding calendar years, they are not required to report those transactions on the HMDA LAR.

Commentary - Paragraph 3(c)(12)

1. General. Section 1003.3(c)(12) provides that an open-end line of credit is an excluded transaction if a financial institution originated fewer than 500 open-end lines of credit in either of the two preceding calendar years. For example, assume that a bank is a financial institution in 2018 under § 1003.2(g) because it originated 50 closed-end mortgage loans in 2016, 75 closed-end mortgage loans in 2017, and met all of the other requirements under § 1003.2(g)(1). Also assume that the bank originated 75 and 85 open-end lines of credit in 2016 and 2017, respectively. The closed-end mortgage loans that the bank originated or purchased, or for which it received applications, during 2018 are covered loans and must be reported, unless they otherwise are excluded transactions under § 1003.3(c). However, the open-end lines of credit that the bank originated or purchased, or for which it received applications, during 2018 are excluded transactions under § 1003.3(c)(12) and need not be reported. See comments 4(a)-2 through -4 for guidance about the activities that constitute an origination.