This is definitely not legal advice, but in order for a progam like this to work at my bank - we would do all of the regular disclosures related to Home Equity - then set the line to tie into customer checking account, so when the credit/debit card is used and funds are not available, the line would advance to cover the amount, if not available. Your Home Equity disclosure/note would spell out how this line would advance or be used for this particular product. You would NOT want it to be tied to a savings or money market account because of the POS limitations of 3 per month. Just my opinion.