Is there any disclosures required when a HMDA loan has a rate spread in excess of 3% or 5%. HOEPA loans require disclosures to be given.

To the best of my knowledge, there is no disclosure for loans that exceed the 3/5% on the HMDA Rate Spread calculations.

Agreed. There is nothing special here as it is a LAR entry. 18 months from now there may be explanation entries when consumer groups start asking "why", but for now there is nothing additional.

What was the intent for asking for this information anyway? As it relates to the HMDA rate spread.

My speculation is as HOEPA loans are identified on the LAR, FRB can track numbers and dollar amounts in a variety of ways, including area concentrations due to geocoding info.
It can produce information as to the amount of HOEPA transactions being produced by regulated institutions, and be a determinate factor in deciding if any additional regulations are required.

Regulators will also be able to single out individual loans when conducting in house examinations.