I appreciate the help gents.
So back to question two: The rules of 1002.13 apply to even if the property used as security for the line will not be the primarily residence, correct? Our software provider is insistent that property being used as collateral has to also be the property being purchased as well, or 1002.13 is not applicable. It seems like they are ignoring the definition of 'new personal residence' in the commentary.
In other words, they state: If HELOC is using collateral of property A as security for the purchase of property B, which is to be new primary residence, then 1002.13 only applies if HELOC will be secured by B as collateral, but since it is to be secured by property A, which is not being purchased since it is already owned, then 1002.13 doesn't apply.