When we put either yes or no to the HOEPA column of the HMDA LAR, do we need to have documentation for all of the "no's" the same as for the "yes"? In other words, our lenders will do a HOEPA test and if it does come out to be a HOEPA loan, their test sheet will be in the file. Does this test sheet also need to be in the file for every one that is not HOEPA?

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Does this test sheet also need to be in the file for every one that is not HOEPA?

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IMO no. However, without the sheet how does one know it did not meet HOEPA triggers? I ran a series of tests on all our loan products to determine what term, rate, dollar amount etc we would have to be concerned with. These worksheets are kept with my audit material and show that as long as the loan is >= to X with X terms, etc. the loan will fall below HOEPA thresholds.

We keep one in every file to prove that we did the test.

We have one in each file where APR is greater than 8% or the fees are greater than $499.