From the OSI to 1002.13(b):
6. Inadvertent notation. If a creditor inadvertently obtains the monitoring information in a dwelling-related transaction not covered by § 1002.13, the creditor may process and retain the application without violating the regulation.
The loan officers are so used to collecting for dwelling secured loans, they tend to forget and automatically collect for HELOCs.
However if this is consistently happening among your originators then I would have to opine they are not "inadvertently" collecting the information and they are routinely collecting the information as part of their application process. In that case you have violations.
The opinions expressed are mine and they are not to be taken as legal advice.