I would agree with raitchjay based on a strict read of the Reg.
If you asked about a car loan being financed with additional monies to payoff a credit card, you wouldn't be able to claim an exemption because funds are also going elsewhere. That exemption is based on "Any credit transaction that is expressly intended to finance the purchase of a motor vehicle when the credit is secured by the vehicle being purchased;" and I would emphasize "expressly intended to finance the purchase" whereas the exception you're looking for is based not on funds disbursement, but collateral, "secured by an interest in a dwelling". While some examples are given, I read those as inclusive, not exclisive (as in these are the only qualifiers.)
Exceptions. Notwithstanding paragraph (f)(1) of this section, consumer credit does not mean:
(i) A residential mortgage, which is any credit transaction secured by an interest in a dwelling, including a transaction to finance the purchase or initial construction of the dwelling, any refinance transaction, home equity loan or line of credit, or reverse mortgage;
My opinions are not necessarily my employers.
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell