We are about to start financing temporary loans to purchase a mobile home, prepare the site, and move the mobile home on the site. After the mobile home is affixed to the site, we will then be paid off by the permanent financing creditor. It appears these loans are triggering HOEPA requirements due to the short term of the loan (six months). The lender calls these "interim construction" loans, but is my opinion that these are not considered construction loans for the purpose of this reg and will not be exempt from HOEPA. Am I correct?
Last edited by Shondra; 05/02/19 06:27 PM.