This question may expose my lack of lending knowledge, but I want to be sure I understand correctly. In reviewing Reg Z rules for Private Education Loans, it states it does not include open end credit or any loan that is secured by real property or dwelling. My interpretation would be that HELOC's are then NOT covered or considered Private education loans, even with the direct product solicitation indicating the consumer may use them for college expenses. So if a new customer came in wanting to open a HELOC expressly for the education expenses, it still wouldn't trigger the education disclosures required in 1026.47?

Correct, a HELOC would not be covered for both reasons (open-end credit and secured by real property or a dwelling).

From the Commentary (my emphasis added):

iii. Examples. The creditor must comply only if the extension of credit also meets the other parts of the definition of private education loan. For example, if the creditor uses a single application form for both open-end and closed-end credit, and the consumer applies for open-end credit to be used for postsecondary educational expenses, the extension of credit is not covered. Similarly, if the consumer indicates the extension of credit will be used for educational expenses that are not postsecondary educational expenses, such as elementary or secondary educational expenses, the extension of credit is not covered. These examples are only illustrative, not exhaustive.