May 8, 2013 at 1:30 am EDT
#2984
rcooper
Member
From my understanding of the information you have provided, these loans would not be subject to HOEPA/12 CFR 1026.32. However, if you were to do a refinance, home-improvement, etc. involving one of these properties that loan would be subject to HOEPA. And, as you mentioned, the HOEPA exemptions will be changing January 10, 2014.