Are bridge loans that the borrower does not intend to convert into permanent financing subject to RESPA or HMDA?

Both the RESPA and HMDA regulations exempt “temporary financing” (“such as bridge or construction loans” or “such as a construction loan,” respectively). 24 CFR 3500.5(b)(3) (RESPA); 12 CFR 1003.4(d)(3) (HMDA). But, if a short-term loan is not designed to “bridge” a borrower to a longer-term, permanent loan, it is not considered temporary financing. As explained in the FFIEC’s HMDA FAQs (Temporary Financing): 

[F]inancing is temporary if it is designed to be replaced by permanent financing of a much longer term. A loan is not temporary financing merely because its term is short. For example, a lender may make a loan with a 1-year term to enable an investor to purchase a home, renovate it, and re-sell it before the term expires. Such a loan must be reported as a home purchase loan.