Gaps in the record
It reported 103 loans in 2018 and 51 in 2019. It filed no report for 2020, 2021, 2022 or 2024; those are gaps in the record, not years without lending. Since 2020 a bank making fewer than 100 closed-end loans a year need not report, which could account for them. It reported 24 loans in 2023 and 25 in 2025, fewer than the 33 typical of similar lenders, national banks making between half and twice as many loans.