There is no exception for a mortgage merely because of its priority. Such a mortgage may, however, qualify for an exemption for other reasons. For example, a Home Equity Line of Credit (HELOC), which is often secured by a second mortgage, is not covered since it is an “open-end credit” transaction. It would not be covered even if it was a first mortgage since the TRID Rule only governs “closed-end credit” transactions. (“Closed-end credit means consumer credit other than ‘open-end credit’” 12 CFR 1026.2(a)(10))