What are the early disclosures required (within 3 business days) on a closed-end loan (2nd lien) refinance of investment property?

My answer was none, but wanted to make sure. In this case, since the loan is being written as a home equity loan and not a busines loan, we were going to send a GFE and TIL just so they understand what the costs will be, etc.

Is this an appropriate way to handle it?

Regardless of the collateral, business purpose loans are exempt from both RESPA (3500.5) and Reg. Z (226.3).