I've been trying to determine if there's a HOEPA exemption from a 12 month bridge loan that pursuant to 1026.32(a)(1) which provides that HOEPA applies to high cost mortgages secured by a principal dwelling. I don't see any exemption. I've been coming across materials which appear to purport that 12 month bridge loans to purchase a principal residence is subject to HOEPA. But the only exemption I see is an exemption for the balloon payment requirement. Is it that somehow based on taking out the balloon payment changes the HOEPA calculation? Or is there no basis for excluding a 12 month bridge loan secured by a principal dwelling?

There is no temporary financing exemption in Section 32.