A HELOC that offers segmenting portions of the variable line into a fixed rate for a specific term, while feeding the paid down balance back into the available LOC is still considered part of the initial open-end transaction, correct? And the LOC and fixed segments are subject to High Cost limitations, not HPML, right?

My colleagues believe the fixed segments may be subject to HPML limitiations, but I think the whole line AND the fixed segments are only subject to the initial account opening High Cost limitations, as it is still open-end credit.

It is one and done. Activating a feature previously disclosed within the account after the account is open does not require anything new or additional considerations.