I don't find how we show that we informed the customer about HOEPA. Do we keep a signed HOEPA disclosure in the loan file showing that we did disclose this to the customer?

The easiest way is to have a customer-signed copy of the disclosure in the file, dated at least 3 days before the closing date of the loan. This is not required by the regulation, however.

Another way to document that the disclosure was given is to build the process into your written procedures. Include the disclosure on your pre-closing checklist, along with the date it was given and the initials of the person who provided or mailed them. Then, include an unisgned copy of the notice in the file.