On page 13 Section V of the CFPB's "2013 Home Ownership and Equity Protection Act (HOEPA) Rule is the source of my confusion. The first sentence reads as follows "You calculate the APR that you use to determine if a transaction is a high-cost mortgage differently from the APR that you disclose on your TILA disclosures.
They didn't say, it "may" be different. Well, if it's a fully amoritized fixed-rate loan, with no change in rate from time of lock, it will be the same APR as is disclosed on the TILA, right????