Hello, I am posting this on the HMDA thread because this thread gets more love than HOEPA. For calculating the rate spread for the HOEPA high cost APR test, can I just use the HMDA calculator? The site notes that the calculation is different, but if I populate the calculator right, can't I just use it to see the spread and so long as it's under 6.5, I'm good?

Here's the calculator I am referring to.

https://ffiec.cfpb.gov/tools/rate-spread

Thank you.

If you separately calculate the APR generated for the HOEPA test (it may not be what is on your CD depending on the loan type), then yes, you can use it for that purpose.