You are correct that this loan is actually a HELOC. It requires the early HELOC disclosure AND the booklet, "What you Should Know About Home Equity Lines of Credit" at the time of application. HELOCs typically do not require any of the RESPA disclosures (GFE, Servicing Disclosure, HUD form). If your bank offers credit insurance on these products you'd need to provide the "at application" insurance disclosure.
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