Is HOEPA Applicable to Bridge Loans?

The only loans exempt from HOEPA are: (226.32(a)(2))

1. Residential Mortgage Transactions (the definition can be found in 226.2)
2. Reverse mortgages subject to 226.33
3. Open-end credit plans subject to Subpart B of Reg. Z

Therefore, taking the time to read the exemptions and the definitions the answers would be (assuming they are not reverse mortgages or an open-end credit plan):

1. No.
2. Yes.
3. Yes.

First published on BankersOnline.com 11/21/2005