Our HELOCs and HEILs secured by a principal dwelling have very little to no fees. In these cases, are we still required to do the points and fees test to see if the line/loan will be High Cost? In other words, will examiners be looking for proof that we tested each and every covered loan?

How else will you prove to them that they are not.

Are your fees and pricing standardized so that there is no variation between borrowers? In those cases, a test done on the category when any component changes would be sufficient.