A shrinking handful
The bank made 52 loans in 2018 and 36 in 2019. It filed no report for 2020 to 2022, when a bank making fewer than 100 closed-end loans a year need not report, so those years are gaps in the record, not years without lending. Since it resumed, its count has fallen from 21 to 15 to 12. The typical similar lender, a national bank making between half and twice as many loans, made 21.