You see conflicting information on this, but I thought that ECOA (Reg B) required you to get the government monitoring information if the HELOC was to purchase or refinance the principal dwelling of the person.
You must get government monitoring information If the answer is Yes to all of the following:
1. Is the applicant a natural person?
2. Does the application involve the purchae or refinance of a dwelling?
3. Doe the dwelling contain one to four (1-4) units?
4. Is the dwelling (or will it become within 1 year) the applicant’s PRINCIPAL DWELLING?
5. Is the dwelling collateral for the loan?