As has been said several times in the string above, transactions to or from a HELOC cannot be subject to Regulation E because a HELOC is not a consumer asset account.
So, if a check from a HELOC is converted, it's subject to NACHA rules but not subject to Reg. E. It will, of course, be subject to Regulation Z.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8