Paragraph 4(a)(13)
1. HOEPA status—not applicable. If the covered loan is not subject to the Home Ownership and Equity Protection Act of 1994, as implemented in Regulation Z, 12 CFR 1026.32, a financial institution complies with § 1003.4(a)(13) by reporting that the requirement is not applicable. If an application did not result in an origination, a financial institution complies with § 1003.4(a)(13) by reporting that the requirement is not applicable.
Loans that have to be tested for HOEPA (consumer purpose and secured by the consumer's primary residence) ARE subject to HOEPA, so as Boaty says, you can't put NA for those. It either is or is not a HOEPA loan, but not NA.
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I'm fixin' to fix that.