If you are considered a “small filer” for HMDA, it basically means you don’t have to report as much data as large filers. There are approximately 25 data fields that small filers are exempt from reporting. Some of those include the Introductory Rate Period, Origination Charges, Multifamily Affordable Units, Combined Loan-to-Value Ratio, etc. Such fields will be completed with either “Exempt” or “1111”; so, they can’t just be left blank. Small filers could choose to report exempt fields voluntarily; however, they need to be aware that, if they do, they must provide ALL the related data included within that section. For example, if small filers voluntarily report credit score, the credit score model must also be reported.
David explains more in the video.