It would have to be open-end credit to be a HELOC.
Section 1026.40—Requirements for Home-Equity Plans
1. Coverage. This section applies to all open-end credit plans secured by the consumer's dwelling, as defined in §1026.2(a)(19), and is not limited to plans secured by the consumer's principal dwelling. (See the commentary to §1026.3(a), which discusses whether transactions are consumer or business-purpose credit, for guidance on whether a home equity plan is subject to Regulation Z.)
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The opinions expressed are mine and they are not to be taken as legal advice.