We have been asked to do a "Bridge Loan" to assist a client. Out loan would be against property A to help with equity to buy property B. Our loan would be secured by property A and would be a 12 month closed end balloon and the rate 6%.

My homework indicates that this loan is exempt from the HPML issues based on the term. We will do a GFE and TIL.

Any other compliance issues we need to look out for?

Thanks

If the loan is to bridge the gap in financing until property A sells, then they will pay down and refi for longer term, it's temporary and exempt from RESPA and HPML requirements.

A 12 month balloon loan with P&I payments would not be exempt from HPML.

If it is truly a temporary bridge loan then it is exempt from RESPA, 1026.19(a) & .35 and HMDA.

If property A is the consumer's primary residence rescission will apply.

Thanks to both for your feedback.

The payment structure will be interest only monthly with princiapl and interest due at maturity.

The property is located in an active market and we anticipate it will sell and in 3-4 months we are out of the deal. No renewals will be permitted.