New to lending compliance.....
I was told that it could be HOEPA if the fees are greater than $499. Also,if the HELOC is 8 or 10% points above the comparable T-Bill, that doesn't throw it into HOEPA.
Is this correct?

226.32 exempts:

purchase transactions;
reverse mortgages;
and open-end (most commonly HELOCs) credit plans.

HOEPA only applies to closed end mortgage transactions secured by principal residences. This is a federal regulation. State regulations may be more restrictive.