I know that on a HELOC, which is secured by the primary residence, used for remodeling a bathroom, we do not collect GMI under Reg B. If the borrower then refinances that same HELOC, which is still secured by the primary residence, do we collect GMI? We have conflicting opinions here on whether GMI is required since the HELOC is secured by the primary residence and is a "refinance". However, the HELOC is not to purchase the primary residence.