for HELOC's we do but it will stop once the loan get's coverted to a 15 year mortgage loan.
Then you are converting an open-end credit to closed-end credit which would be a refinancing under Reg. Z. You are replacing the open-end obligation with a closed-end obligation and you must provide all applicable closed-end disclosures and follow all closed-end requirements.
The opinions expressed are mine and they are not to be taken as legal advice.