If a TIL notes under prepayment that the borrower may have to pay a minimum finance charge and the loan is a HOEPA loan, isnt this a violation of 12 CFR 226.32?

Generally minimum finance charges are only allowed under state law on simple interest transactions. They allow you to collect an amount set my state law in case the loan pays off before the loan accrued that much in interest. For example IN's minimum finance charge is currently $42.

If this is not a simple interest loan then you may have a problem unless you can justify it under the exception allowed at 226.32(d)(7).

Thank you. Could you please tell me where I can find the amount for the state of Tennesse?

We don't do loans in TN. I would suggest you search their state Web site for their Department of Financial Institutions or Department of Banking. Or you can post the question in the TN state forum.