I just want to confirm that all HMDA reportable transactions are excluded, even if we are not required to report them. We are exempt from open-end HMDA reporting. If I read the preamble correctly, those loans would still be exempt from 1071, correct?

Any transactions reported under HMDA would not be reported under Section 1071. However, keep in mind that business purpose loans that are secured by dwelling property may not be reported under HMDA under certain circumstances, as specifically exempted under §1003.3(c) (10).