Someone please help! I am doing an audit on high risk home loans and am testing my loans against the City of Chicago / Cook County Predatory Lending Oridnances. Heres my problem. It appears that these rules also apply to HELOCS and I am not sure how to do the rate comparison. Does anyone #1 agree that it does include HELOCS and #2 if it does, how do you do the APR test? Thanks!