Based on lien status, not product type. First lien, you abide by the rule and timeframes.
1002.14(a)(1) In general.
1. Coverage. Section 1002.14 covers applications for credit to be secured by a first lien on a dwelling, as that term is defined in § 1002.14(b)(2), whether the credit is for a business purpose (for example, a loan to start a business) or a consumer purpose (for example, a loan to purchase a home).
_________________________
I don't repeat gossip, so listen closely...