I hate to even ask as this should be basic knowledge, but what is an alternative mortgage transaction? We have HELOCs that have variable rates and closed-end mortgages that are ARMs. Are either of these considered an alternative mortgage transaction?

https://www.law.cornell.edu/uscode/text/12/3802

Closed-end ARM loans are definitely covered. I am not totally sure about HELOCs and that would need a little more research.