HOEPA and Purchase/Rehab Loan

Let's hear your thoughts on HOEPA and it's application to a purchase/rehab loan with a term of 12 months? The loan is 12 months, interest only for the purchase/rehab of a principle residence that will then be taken out by a secondary market broker.

I tend to think this meets the spirit and intent of the construction exemption, but it is not initial construction.

Thoughts? Because of the short term, the APR is naturally inflated.

I see no exemption from HOEPA.