Section 32 applies to transaction secured by the consumer's principal residence. It does not say "the borrower's" principal residence.
The loan you describe IS secured by a consumer's principal residence....therefore it would be covered. Part of the purpose of this section of Reg Z is to guard against predatory lending for loans secured by homestead property to prevent consumers from losing their homesteads.
_________________________
The more you sweat in training, the less you bleed in battle.......