We are closing a loan that does not calculate to be HOEPA, unless we add in the 2.5% YSP being collected after closing. I have not been able to determine whether the YSP should be inlcuded in the HOEPA calculation or not. Any help would be appreciated. Thank you.

We, the bank would collect it after delivering it to the investor. Thank you.

I'm assuming the bank is collecting it from the investor. In that case, as long as the borrower is not paying any portion of that cost, it doesn't come into the HOEPA calculation.