Shouldn't a bridge loan secured by current primary residence for 12 months to purchase primary residence require a HOEPA worksheet?

Interesting question to me as i don't see many bridge loans. The only possible HOEPA exemption would seem to be if a bridge loan meets the definition of a "residential mortgage transaction", which on the surface it might appear to, but when you look at that definition you see: 24) Residential mortgage transaction means a transaction in which a mortgage, deed of trust, purchase money security interest arising under an installment sales contract, or equivalent consensual security interest is created or retained in the consumer's principal dwelling to finance the acquisition or initial construction of that dwelling. (emphasis mine) So maybe it hinges on whether your security is the current primary residence alone or if it includes the primary residence being purchased? Sorry...hope i haven't muddied the waters.