We think we have uncovered a violation for a loan that closed 3 months ago. No HoEPA disclosures were given or signed. Customers were properly given the opportunity to rescind. Upon completing the calculations during the review process, we have determined that it is a HOEPA loan. Normally, these calculations are done before the loan closes.
What do we need to do to correct this situation? Do we need to reimburse the borrower?