The HELOC is a dwelling secured loan that has been refinanced into another dwelling secured loan. Since the new loan is no longer a HELOC it no longer is optional reporting and must be reported as a refinancing.
I agree with Dan. To say it another way, your answer comes in two parts: 1) The new loan "satisfies and replaces a loan secured by a dwelling to the same borrower." 2) The new loan is not a LOC so it does not qualify for the exception.
Therefore, the loan is reportable.
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Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.
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