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A credit union originated 19 closed-end mortgages in one year and 31 in the next. It meets every other institutional test under Regulation C.

Correct Answer

A) Not covered for closed-end: the 25-loan test needs both years met

The closed-end loan-volume test looks at each of the 2 preceding calendar years, and 19 in the earlier year fails it however large the later year is. Other choices: adding the years together is not the test; reaching 31 in the most recent year alone is not enough; and credit unions are covered institutions when they meet the tests. Source: 12 CFR 1003.2(g)

Answer Options
A
Not covered for closed-end: the 25-loan test needs both years met
B
Not covered, since a credit union is outside Regulation C entirely
C
Covered for closed-end, since the 2-year total of 50 clears the bar
D
Covered for closed-end, because the most recent year reached 31

Why This Is the Correct Answer

The closed-end loan-volume test looks at each of the 2 preceding calendar years, and 19 in the earlier year fails it however large the later year is. Other choices: adding the years together is not the test; reaching 31 in the most recent year alone is not enough; and credit unions are covered institutions when they meet the tests. Source: 12 CFR 1003.2(g)

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