Section 35 states temporary loans such as construction or bridge loans with a term of less than 12-months are exempt for sectoin .35 purposes.

Can we assume that term "temporary" is similar to HMDA and is based more on the fact that it will be replaced with perm financing?

We are doing a 90-day note that will be replaced with permanent financing at the end of that period. Can we safely assume that this would be exempt from HPML and Escrow rules??