If we do a loan secured by the borrower's principal residence that is a High Cost mortgage under the Reg. Z HOEPA rules, is the required HOEPA disclosure now part of the TRID Closing Disclosure or do we still have to give a separate HOEPA disclosure? I can't seem to find a definite answer.

Tx

I have never seen that disclosure in any of my TRID documentation - I am pretty sure it is separate disclosure