LOL! Getting back to the OP, if the loan is for a consumer purpose, and secured by real estate of whatever type (not the real estate to be acquired, in this case), it will be covered by the TRID rules and any other applicable Reg Z requirement (not owner occupied, not a dwelling).
As for the TRID purpose, it won't be a purchase, refi, or construction, so it defaults to Home Equity Loan even though the security won't be his home. The product type will be lender choice considering the customer relationship, security type, etc.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8