Questions and Answers

HOEPA stands for the Home Ownership and Equity Protection Act.  It created the restrictions that are currently placed on what are commonly called "high-cost mortgages."  These are mortgages that have either a high interest rate or high initial fees such that they are subject to special rules under Regulation Z. (Truth-in-Lending).  The special rules can be found in Section 32 of Regulation Z. 

Section 32 applies to a consumer credit transaction that is secured by the consumer's principal dwelling and exceeds either the high interest rate threshold or the high initial fees threshold.  Section 32 does not apply, however, to a "residential mortgage transaction."  A residential mortgage transaction is credit secured by the borrower's principal dwelling where the purpose of the credit is the acquisition or initial construction of the dwelling.  Section 32 also does not apply to reverse mortgages.  Finally section 32 does not apply to open-end credit. 

Since the rules describing the high interest rate threshold at high initial fees threshold are complicated, we will refer you to Section 32 of Regulation Z for the details.  (12 CFR 226.32) 

So the loan you describe would be subject to HOEPA if the loan is secured by the consumer's principal dwelling and it meets either the high interest rate threshold or the high initial fees threshold.  Your own does not appear to fit within any of the exemptions.