If we make 12 month, adjustable rate loans secured by a 2nd lien on a consumer's principal dwelling (not ARMs since 12 months), but may do a renewal at the end of the 12 months, could we be cited for structuring the transaction to avoid ARM requirements?

That and probably ATR, HPML issues, if you are talking about an intentional effort to avoid these regulatory requirement by structuring the loans in this manner. You would need to prove why these loans should be done on a temporary basis.