Are there any exceptions for a HOEPA loan if it is a construction loan? For example, if the proceeds from our loan are being used to construct what will be the consumers primary dwelling, is there any exemptions.
Residential Mortgage Transactions are currently exempt under 1026.32(a)(2). You can review the definition of a RMT at 1026.2(a)(24) and its Commentary to see if your transaction meets the definition.
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The opinions expressed are mine and they are not to be taken as legal advice.