Assuming:
1. "homestead exemption" is a right recognized by state law
2. your email message will not mention any aspect of a product or service, and
3. we're looking only at the act (because I don't remember what the FTC said in its "primary purpose" regulations),
then I don't see any reasonable argument that the proposed message meets the definition of a "commercial electronic mail message." If it's not a CEMM, then it's outside the scope of the act. Enjoy saying "yes" to your lenders on this one--they probably think you're incapable of using that word. :-)
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...gone fishing.