My bank decided that we were not going to make Higher-Priced Mortgage Loans when this rule became effective a couple of years ago. In a HMDA review, this decision has come back to bite us. We now have a loan that meets the definition of a HPML and I’m not sure what corrective actions we need to make. Since we already now have violations of Regulation Z, RESPA and missed the deadline for providing initial escrow account statement, I would appreciate any direction you could give me.

Nothing you can do. Document - re-train and move on to the next opportunity.