Answer:
That is correct. The only typical short-term loan exempt from HOEPA are initial construction loans.
Exceptions to HOEPA and HPMLs
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Question:
Are short term loans (loans that will not be satisfied and replaced with permanent financing; paid out in full instead) subject to HOEPA and HPML?
I see that temporary loans and bridge loans -12 months or less (loans that will be satisfied and replaced with permanent financing) are not subject to HPML.
I believe temporary and short term loans are subject to HOEPA though.
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