Consider that, other than a couple of limited provisions relating to business credit cards, the criterion that an extension of credit be for personal, family or household purposes is the key to whether any part of Regulation Z applies.
If it is a loan for a business purpose, the regulation doesn't apply, and therefore the HELOC provisions of the regulation don't apply, there is no rescission right, HPML isn't an issue, ..... unless your state has a law stating otherwise.
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8